Internal Distributing definition

Internal Distributing means Delphi Corporation, a Delaware corporation.
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Internal Distributing means Ingevity Virginia Corporation, a Virginia corporation.
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Internal Distributing has the meaning set forth in the recitals hereof.
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Examples of Internal Distributing in a sentence

  • Unlike in Example 5, however, Distributing in the 2016 Preamble Example directly and indirectly owns 100 percent of the stock of both P and Internal Distributing.

  • The 2016 Preamble Example, like Example 5, involves a section 351 exchange in which P exchanges assets for Internal Distributing stock with the same value and built-in gain.

  • Thereafter, Internal Distributing (i) contributes one of the P assets to Controlled, and (ii) distributes all of the stock of Controlled to Distributing in a Distribution.

  • As a result, in the 2016 Preamble Example, Distributing could unilaterally eliminate the built-in gain preserved in P’s Internal Distributing stock through an internal restructuring.

  • P then contributes some (but not all) of its assets to a wholly owned subsidiary of Distributing (Internal Distributing) in a transaction to which section 351 applies.

  • The Internal Contribution and the Internal Distribution will qualify as a transaction in which no gain or loss is recognized to Internal Distributing, Internal Controlled, or Distributing, and no amount is included in the income of Distributing, under Section 368(a)(1)(D) and Section 355.2. Provided that the Internal Merger will be treated as a merger of Internal Controlled into Controlled, the Internal Merger will qualify as a reorganization under Section 368(a)(1)(A).

  • For purposes of this Section 8.02(c)(iv), a merger of SpinCo or Internal Distributing (or a member of the applicable SAG) with and into any Person shall constitute a disposition of all of the assets of such entity or such member.

  • The percentages of gross assets of Internal Distributing or of the consolidated gross assets of Internal Distributing and the members of its SAG, as the case may be, sold, transferred, or otherwise disposed of, shall be based on the fair market value of the gross assets of such entity or entities as of the date of the Internal Distribution.

  • Internal Distributing will distribute all of the issued and outstanding stock of Internal Controlled to Distributing (the “Internal Distribution”).

  • As a result, a portion of the Internal Contribution (which had previously been were treated as a tax-free transfer of property to Internal SpinCo for U.S. federal income tax purposes) is recharacterized as an intercompany sale of assets from Internal Distributing to Internal SpinCo, resulting in a deferred intercompany gain to Internal Distributing of $10x.


More Definitions of Internal Distributing

Internal Distributing has the meaning set forth in the Ruling Request.
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Internal Distributing has the meaning set forth in the preamble hereof.
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Related to Internal Distributing

  • Internal Distribution has the meaning set forth in the recitals.

  • Internal Reorganization has the meaning set forth in the Separation Agreement.

  • Local Distribution Company or “LDC” means a Person licensed by the OEB as a “Distributor” in connection with a Distribution System.

  • Final Distribution means any distribution made in redemption of all or a portion of the Up-MACRO Holding Shares pursuant to Section 5.2(a) or 5.2(c) on the Final Scheduled Termination Date, an Early Termination Date or a Redemption Date.

  • Internal dose means that portion of the dose equivalent received from radioactive material taken into the body.

  • Internal Restructuring shall have the meaning set forth in Section 7.02(f) of this Agreement.

  • Final Distributions means, with respect to the Certificates of any Trust on any Distribution Date, the sum of (x) the aggregate amount of all accrued and unpaid interest on such Certificates (excluding interest, if any, payable with respect to the Deposits relating to such Trust) and (y) the Pool Balance of such Certificates as of the immediately preceding Distribution Date (less the amount of the Deposits for such Class of Certificates as of such preceding Distribution Date other than any portion of such Deposits thereafter used to acquire Equipment Notes pursuant to the Note Purchase Agreement). For purposes of calculating Final Distributions with respect to the Certificates of any Trust, any Premium paid on the Equipment Notes held in such Trust which has not been distributed to the Certificateholders of such Trust (other than such Premium or a portion thereof applied to the payment of interest on the Certificates of such Trust or the reduction of the Pool Balance of such Trust) shall be added to the amount of such Final Distributions.

  • External dose means that portion of the dose equivalent received from any source of radiation outside the body.

  • External Debt means obligations (other than the Notes) of, or guaranteed by, the Republic for borrowed money or evidenced by bonds, notes or other similar instruments denominated or payable, or those which at the option of the holder thereof are so denominated or payable, in a currency other than the local currency of the Republic.

  • Final Distribution Date The Distribution Date on which the final distribution in respect of the Certificates is made pursuant to Section 9.01.

  • Internal Use means use of the Sprinklr Services for Customer’s and/or Customer Affiliates’ general business use, solely for the benefit of Customer and/or Customer Affiliates, but does not include use of the Sprinklr Services to provide any services for the benefit of third parties.

  • Taxable Event means any change in control or other event which triggers the imposition of any Excise Tax on any Payment.

  • External Directors means directors appointed and serving in accordance with Sections 239 through 249 of the Companies Law.

  • Spinoff means a transaction in which the Transferor Plan transfers only part of its assets and/or liabilities to the Transferee Plan. The Transferee Plan may be a New Plan that is created in the Spinoff, or it may be a preexisting plan that simply receives part of the assets and/or liabilities of the Transferor Plan.

  • Initial Distribution means the distribution made to holders of Allowed Class C-4 Claims on the Distribution Date.

  • taxable trading means carrying on a trade or business for the principal purpose of raising funds and not for the purpose of actually carrying out the Objects, the profits of which are subject to corporation tax;

  • Assumed Final Distribution Date The Distribution Date occurring in November 2035.

  • Distribution Transaction means any distribution of equity securities of a Subsidiary of the Company to holders of Common Stock, whether by means of a spin-off, split-off, redemption, reclassification, exchange, stock dividend, share distribution, rights offering or similar transaction.

  • Internal Market Buyer means a Market Buyer making purchases of energy from the PJM Interchange Energy Market for ultimate consumption by end-users inside the PJM Region that are served by Network Transmission Service.

  • Rated Final Distribution Date With respect to each Class of Rated Certificates, the Distribution Date in May 2048.

  • taxable service means any service provided or to be provided –

  • internal waters means any navigable river or waterway within the State of California.

  • Coordinated External Transaction means a transaction to simultaneously purchase and sell energy on either side of a CTS Enabled Interface in accordance with the procedures of Operating Agreement, Schedule 1, section 1.13, and the parallel provisions of Tariff, Attachment K- Appendix.

  • Special Distribution has the meaning set forth in Section 11.4.

  • Normal distribution channel means a chain of custody for

  • SpinCo shall have the meaning set forth in the Preamble.