F Reorganization definition
F Reorganization has the meaning set forth in the Recitals.
F Reorganization means a reorganization described by Section 368(a)(1)(F) of the Code. “FCPA” means the Foreign Corrupt Practices Act of 1977, as amended.
F Reorganization means the transaction steps described in the Separation Plan whereby, pursuant to a plan of reorganization within the meaning of Treasury Regulation Section 1.368-2(g), (i) Seller contributes all of the outstanding equity of USCC Services to a newly formed holding company classified as a corporation for U.S. federal income tax purposes that does not hold and has never held more than a de minimis amount of assets and (ii) USCC Services makes an election by properly filing an IRS Form 8832 to change its classification from a corporation to a disregarded entity effective from the day following the contribution (but prior to the transfer of USCC Services to the Company and the Closing Date); which steps (i) and (ii) together are intended to be treated as a reorganization under Section 368(a)(1)(F) of the Code.
Examples of F Reorganization in a sentence
None of the Permits required to be set forth in Section 3.16 of the Seller Disclosure Schedule have been adversely affected as a result of the F-Reorganization or the transactions contemplated by this Agreement or any Ancillary Agreement.
More Definitions of F Reorganization
F Reorganization has the meaning set forth in the recitals of this Agreement.
F Reorganization means a “reorganization” within the meaning of Section 368(a)(1)(F) of the Code;
F Reorganization has the meaning set forth in the preliminary statements to this Agreement.
F Reorganization has the meaning set forth in Exhibit A.
F Reorganization has the meaning specified in Section 9.10(a).
F Reorganization means the transaction in which the Party Shareholders and Non-Party Shareholders contributed all of their stock in the Company to the Seller, in exchange for stock in the Seller (issued to the Party Shareholders and Non-Party Shareholders in proportions identical to the manner in which the stock was held by them in the Company), and the election by the Seller to treat the Company as a Qualified Subchapter S Subsidiary for U.S. federal income tax purposes.
F Reorganization means a mere change in identity, form, or place of organization of one corporation, however effected, pursuant to Section 368(a) (1)(F) of the Code.