Favorable Tax Opinion definition

Favorable Tax Opinion means an opinion of Bond Counsel stating in effect that the proposed action, waiver, or failure to act or other specified fact, condition or circumstance, together with any other changes with respect to the Bonds made or to be made in connection with such action, waiver or failure to act, or fact, condition, or circumstance, will not adversely affect the exclusion of interest on the Bonds from gross income for federal income tax purposes of the recipients thereof.

Favorable Tax Opinion means an Opinion of Counsel stating in effect that the proposed action, together with any other changes with respect to the Bonds made or to be made in connection with such action, (a) will not cause interest on the Bonds to become includible in gross income of the Holders for purposes of federal income taxation, and (b) complies with the terms of this Indenture.

Favorable Tax Opinion has the meaning set forth in Section 2.02(f) hereof.

Examples of Favorable Tax Opinion in a sentence

• No amendment to this Indenture shall be effective unless and until the Bond Administrative Agent receives a Favorable Tax Opinion and the District delivers a copy of the Favorable Tax Opinion to the City.

• Notwithstanding the foregoing, upon a conversion to a Fixed Rate, the Borrower, pursuant to written notice to the Issuer and the Trustee, may elect to provide a Credit Facility for the Bonds if and only if a Favorable Tax Opinion is delivered to the Trustee taking into account the provision of such Credit Facility.

• Respondents have to indicate (i) which review criteria they will use at which moment in the NSD project and (ii) whether they use a review gate.

• Prior to consenting to such an amendment, the Trustee shall receive a Favorable Tax Opinion.

• The Callable Warrants purchased pursuant to this Section (i) shall not be cancelled or retired, but shall continue to be Outstanding, (ii) shall be delivered to, or as directed by, the Issuer, (iii) shall continue to bear interest or accrete value at the rate provided for in this Indenture, and (iv) may not be resold by the Issuer or its nominee without first delivering a Favorable Tax Opinion to the Trustee.

More Definitions of Favorable Tax Opinion

Favorable Tax Opinion means an Opinion of Counsel stating in effect that the proposed action, together with any other changes with respect to the Warrants made or to be made in connection with such action, will not cause interest on the Warrants to become includible in gross income of the Warrantholders for purposes of federal income taxation.

Favorable Tax Opinion means an Opinion of Counsel stating in effect that the proposed action, together with any other changes with respect to the Series 2024 Warrants made or to be made in connection with such action, will not cause interest on the Series 2024 Warrants to become includible in gross income of the Holders for purposes of federal income taxation.

Favorable Tax Opinion means an Opinion of Counsel stating in effect that the proposed action, together with any other changes with respect to the Series 2012-C Warrants made or to be made in connection with such action, will not cause interest on the Series 2012-C Warrants to become includible

Favorable Tax Opinion means an opinion of counsel stating in effect that the proposed action, together with any other changes with respect to the Bond made or to be made in connection with such action, will not cause interest on the Bond to become includible in gross income of the Bondholder for purposes of federal income taxation.

Favorable Tax Opinion means a written tax opinion at a “should” level (or higher) by an independent tax counsel or accounting firm of recognized national standing acceptable to Capital and AS Spinco and upon which Capital and SDS or AS Spinco, as applicable, can rely to the effect that a transaction should not affect the Intended Tax Treatment. Any such opinion shall assume that the Contribution, the Debt Repayment, the Debt Exchange, the Internal Spin-Offs and the External Split-Off would qualify for the Intended Tax Treatment if the transaction did not occur.

Favorable Tax Opinion means a written opinion, reasonably satisfactory to the Trustee, addressed and delivered to the Trustee by a nationally recognized law firm to the effect that the Company will not be a publicly traded partnership taxable as a corporation for United States federal income tax purposes as a result of the issuance by the Company of the Notes.

Favorable Tax Opinion means an Opinion of Counsel stating in effect that the proposed action, together with any other changes with respect to the Bonds made or to be made in connection with such action, will not cause interest on the Bonds to become Taxable. Federal Securities shall mean noncallable, nonprepayable, direct obligations of, or obligations the full and timely payment of which is guaranteed by, the United States of America, excluding unit investment trusts and mutual funds. Financing Documents shall mean the Indenture, the Remarketing Agreement, the Tender Agent Agreement, the Lease Agreement and the Credit Agreement.