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

Internal Restructuring means (i) any internal restructuring (including by making or revoking any election under Treasury Regulations Section 301.7701-3) involving SpinCo or any of its subsidiaries or (ii) any direct or indirect contribution, sale or other transfer by SpinCo to any of its Subsidiaries of any of the assets contributed or transferred to SpinCo as part of the Contribution or pursuant to the Separation and Distribution Agreement.

Internal Restructuring shall have the meaning set forth in the Separation Agreement.

Examples of Internal Restructuring in a sentence

SpinCo shall not engage in, cause or permit any Internal Restructuring during or with respect to any Tax Period (or portion thereof) ending on or prior to the Distribution Date without obtaining the prior written consent of Parent (such prior written consent not to be unreasonably withheld), other than pursuant to the Plan of Reorganization.
SpinCo shall provide written notice to Parent describing any Internal Restructuring proposed to be taken during or with respect to any Tax Period (or portion thereof) beginning after the Distribution Date and ending on or prior to the two-year anniversary of the Distribution Date and shall consult with Parent regarding any such proposed actions reasonably in advance of taking any such proposed actions and shall consider in good faith any comments from Parent relating thereto.

More Definitions of Internal Restructuring

Internal Restructuring has the meaning set forth in the Recitals of this Agreement.

Internal Restructuring has the meaning set forth in Schedule B.

Internal Restructuring has the meaning set forth in Exhibit [B].4

Internal Restructuring has the meaning set forth in the recitals hereto.

Internal Restructuring shall have the meaning set forth in the Distribution Agreement.

Internal Restructuring has the meaning set forth in Section 1.01(b).