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

• If a member of the Acquiror Group notifies Parent that it desires to take an action that would reasonably be expected to be inconsistent with the covenants contained in Section 9(b), then the Parent Group shall cooperate in good faith with the Acquiror Group to obtain the Favorable Tax Ruling and/or a Favorable Tax Opinion.

• No amendment may be made to the Bond Documents unless the Bond Trustee receives a Favorable Tax Opinion.

• Notwithstanding the foregoing, in no event shall any Bond commence bearing interest at the new Direct Purchase Rate for a new Direct Purchase Rate Period unless and until a Favorable Tax Opinion has been delivered to the Purchaser Agent and the Corporation with respect to such change.

• The Indenture permits the Issuer to consolidate with or merge into any corporation, or transfer its property substantially as an entirety to any municipal or public corporation, if (i) payment of the Bonds and the performance and observance of the agreements and covenants of the Indenture are expressly assumed in writing by the surviving or successor corporation and (ii) the Issuer delivers to the Trustee a Favorable Tax Opinion.

• No amendment may be made to this Indenture or the Lease Agreement unless the Trustee receives a Favorable Tax Opinion.

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 2012-A Warrants made or to be made in connection with such action, will not cause interest on the Series 2012-A Warrants to become includible in gross income of the Holders 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 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 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.

Favorable Tax Opinion means an opinion of counsel with experience in the matters to be covered in the opinion 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.

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.