Federal Tax Treatment. Notwithstanding anything to the contrary contained in this Agreement or any document delivered herewith, all persons may disclose to any and all persons, without limitation of any kind, the federal income tax treatment of the Notes, any fact relevant to understanding the federal tax treatment of the Notes, and all materials of any kind (including opinions or other tax analyses) relating to such federal tax treatment.
Federal Tax Treatment. Subject to the qualifications, limitations and assumptions set forth in the Registration Statement, the General Disclosure Package and the Prospectus, the Company expects to be treated as a foreign corporation for U.S. federal income tax purposes, taking into account Section 7874 of the Code.
Federal Tax Treatment. Qualified ABLE Program. CalABLE is designed to be, and is intended to satisfy the requirements for treatment as, a qualified ABLE program under Section 529A. The IRS provides important information on the taxation of qualified ABLE programs in IRS Publication 907 available at xxxxx://xxx.xxx.xxx/pub/irs- pdf/p907.pdf. Contributions. Contributions to an Account generally will not result in taxable income to the Account Owner. Contributions are made on an after-tax basis. A contributor may not deduct the contribution from income for the purposes of determining federal income tax liability.
Federal Tax Treatment. The Parties intend that the transactions effected pursuant to this Plan of Merger shall be treated for federal income tax purposes (i) as to Properties LLC, as a complete liquidation of a wholly-owned subsidiary (Properties LLC) into its owner (Pioneer USA) pursuant to Sections 332, 334(b) and 337 of the Internal Revenue Code of 1986, as amended (the “Code”), and (ii) except to the extent provided in (i), as disregarded. With respect to Properties LLC, this Plan of Merger is intended to constitute a plan of complete liquidation in complete cancellation or redemption of all of its membership interests (treated as stock for federal income tax purposes) under Section 332 of the Code.
Federal Tax Treatment. (a) Notwithstanding anything herein to the contrary, for United States federal income tax purposes, the parties hereto agree to treat the sale of Receivable Interests pursuant to this Agreement as a loan secured by the Receivables.
Federal Tax Treatment. Contributions to the Custodial Account which do not exceed the Exclusion Allowance and the special limitation on elective salary reduction contributions are excludable from the gross income of the Employee. Dividends and capital gains distributions on securities held in the Custodial Account are accumulated tax-free until distribution of the Account. Distributions from the Custodial Account are taxed to the Employee under Section 72 of the Code as ordinary income in the year(s) during which such distributions are received. If all contributions have been excluded from the Employee's taxable income, the Employee's cost basis in the Custodial Account is zero and distributions therefrom will be taxed as ordinary income as received. If any part of the contributions were taxable to the Employee, which would be the case for example if the Exclusion Allowance was exceeded, the aggregate amount of all such taxable contributions comprises the Employee's cost basis. If such an Employee takes distributions from the Custodial Account in installments, then all of the installments will include a portion excludable from tax as a return of the Employee's cost basis. In the event of the death of an Employee prior to the full distribution of his or her Custodial Account, the remainder is taxed as income to his or her beneficiary as received. Like the Employee, however, the beneficiary may exclude any remaining cost basis which the Employee had in the Custodial Account. Under certain circumstances, a death benefit exclusion is available to the death beneficiary of an Employee. In such cases, the beneficiaries of the Employee are entitled to an exclusion of $5,000 (aggregate total for all beneficiaries) for income tax purposes. If the deceased Employee was a participant in a qualified trust or annuity plan of the Employer, as well as a participant in the Custodial Account, the exclusion must be allocated between distributions for both sources. Section 403(b)(7) was added to the Code by the Pension Reform Act of 1974. No final regulations pertaining specifically to that section have as yet been adopted by the Internal Revenue Service. If final regulations are adopted requiring changes to the First Investors Corporation 403(b) Custodial Account Agreement, it is the intention of First Investors Corporation to amend the Agreement to comply with any such regulations. It should be understood, in addition, that the foregoing discussion of federal income tax consequences is not exhaus...
Federal Tax Treatment. For Federal income tax purposes, the parties --------------------- intend that the Merger be treated as six separate transactions occurring as follows: (i) the merger of CF Data into CFDC will be treated as a tax free liquidation under Section 332 of the IRC; (ii) the merger of CTI into CFDC will be treated as a tax free liquidation under Section 332 of the IRC; (iii) the merger of NRS into CFDC will be treated as a tax free liquidation under Section 332 of the IRC; (iv) the merger of NPS into CFDC will be treated as a tax free liquidation under Section 332 of the IRC; (v) the merger of CFDC into CMI will be treated as a tax free reorganization under Section 368(a)(1)(A) of the IRC; and (vi) the merger of Arizona Non-Surviving Corp into CMI will be treated as a tax free reorganization under Section 368(a)(1)(A) of the IRC. Each of the Non- Surviving Corps and Surviving Corp shall report such Merger consistent with this Section 1.3 for Federal income tax purposes. -----------
Federal Tax Treatment. For U.S. federal tax purposes, the Reorganization is intended to qualify as a partnership merger within the meaning of Section 708(b)(2) of the Internal Revenue Code of 1986, as amended (the “Code”) and Treas. Reg. § 1.708-1(c)(1). In accordance with Treas. Reg. § 1.708-1(c)(1), (i) the “resulting partnership” shall be treated as a continuation of the Acquiring Fund and (ii) the Acquired Fund shall terminate and its taxable year will close. In accordance with Treas. Reg. § 1.7081(c)(3)(i), the Reorganization will follow the “asset-over form” for U.S. federal tax purposes, pursuant to which, (i) the Acquired Fund will be deemed to contribute all of its assets and liabilities to the Acquiring Fund in exchange for interests in the Acquiring Fund, and (ii) immediately thereafter, the Acquired Fund will be deemed to distribute the interests in the Acquired Fund to its partners in liquidation of the Acquired Fund.
Federal Tax Treatment. For federal income tax purposes, it is intended that the Interim Merger will qualify as a "qualified stock purchase" under Section 338(d) of the Internal Revenue Code of 1986, as amended (the "Code") and that the Bank Merger will qualify as a tax free subsidiary liquidation under Section 332 of the Code, as set forth in Revenue Ruling 90-95, 1990-2 C.B.67. General Bank hereby confirms and agrees, that it shall not, with respect to the Interim Merger, make an election under Section 338 of the Code (or any corresponding provision of state or local law) to have Liberty Bank treated as if it had sold all its assets for federal (and/or state or local) income tax purposes.
Federal Tax Treatment. The Parties acknowledge that for U.S. federal income tax purposes, the acquisition of the Deep South Shares will be treated as a transfer of the assets of the Deep South Qualified Sub-S Subsidiaries to Buyer, followed by Buyer’s transfer of these assets to the capital of the Deep South Qualified Sub-S Subsidiaries in exchange for the respective stock of the Deep South Qualified Sub-S Subsidiaries.
