Internal Distributions definition

Internal Distributions means the First Internal Distribution, the Second Internal Distribution, and the Third Internal Distribution.

Internal Distributions means the distributions of stock within the Remainco Existing Group that are described in the US Ruling as qualifying for nonrecognition treatment under Sections 355 and 368(a)(1)(D) of the Code;

Internal Distributions means the distributions of SPINCO common stock by Teledyne Industries, Inc. to TDY Holdings, LLC, a Delaware limited liability company wholly owned by ATI, and by TDY Holdings, LLC to ATI. IRS means the U.S. Internal Revenue Service.

Examples of Internal Distributions in a sentence

• Moreover, this office has not verified any information pertaining to, and has made no determination regarding, whether any of the Internal Distributions or the External Distribution (each as defined below): (i) satisfies the business purpose requirement of Treas.

• It complains,however, that NSSD’s engineers were “alarmed” by the cost estimate.

• COSMOmic: A Mechanistic Approach to the Calculation of Membrane-Water Partition Coefficients and Internal Distributions within Membranes and Micelles.

• Wilber gives an example from early child development that helps to illustrate this process.

• Distributing 4 will distribute, on a pro rata basis, the stock of Controlled 2 to Distributing 4’s shareholders (the “External Distribution,” and together with the Internal Distributions, the “Distributions”).

More Definitions of Internal Distributions

Internal Distributions means the separation of (a) the UTC Assets and UTC Liabilities from the Carrier Assets and Carrier Liabilities and/or the Otis Assets and Otis Liabilities, (b) the Carrier Assets and Carrier Liabilities from the UTC Assets and UTC Liabilities and/or the Otis Assets and Otis Liabilities, and/or (c) the Otis Assets and Otis Liabilities from the UTC Assets and UTC Liabilities and/or the Carrier Assets and Carrier Liabilities, in each case, (i) held by certain subsidiaries of UTC and (ii) in a transaction intended to qualify, for Federal Income Tax purposes, as a distribution that is generally tax-free pursuant to Section 355(a) (or Sections 355(a) and 368(a)(1)(D)) of the Code.

Internal Distributions means the First Internal Distribution and the Second Internal Distribution, taken together.

Internal Distributions has the meaning set forth in the Recitals.

Internal Distributions has the meaning set forth in the Tax Matters Agreement.

Internal Distributions shall have the meaning set forth in the recitals hereto.

Internal Distributions means the transactions described in Schedule B.

Internal Distributions shall have the meaning set forth in Section 3.1.