Internal SpinCo definition

Internal SpinCo has the meaning set forth in the recitals hereof.
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Internal SpinCo means Delphi Powertrain Systems, LLC, a Delaware limited liability company.
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Internal SpinCo means Varex Imaging International Holdings B.V., a besloten vennootschap organized under the laws of the Netherlands, and a direct wholly owned subsidiary of VMSN.
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Examples of Internal SpinCo in a sentence

  • SpinCo further agrees that, from the date hereof until the first day after the Restriction Period, it will cause Internal SpinCo to (A) maintain its status as a company engaged in the Internal SpinCo Active Trade or Business for purposes of Section 355(b)(2) of the Code and (B) not engage in any transaction that would result in it ceasing to be a company engaged in the Internal SpinCo Active Trade or Business for purposes of Section 355(b)(2) of the Code.

  • For the External SpinCo Pre-Spin 2014 Period, the Mexican Maquilas, which are disregarded as entities separate from Internal SpinCo for U.S. federal income tax purposes and which are members of the External SpinCo Group, have $100x of taxable income under both United States and Mexican Income Tax law.

  • These files or records contain information regarding litigation or antici- pated litigation, which includes judicial and administrative proceedings.

  • The Mexican Sale results in $20x of taxable gain under Mexican Income Tax law and a deferred intercompany gain of $20x under United States Income Tax law (which is taken into account by Internal SpinCo immediately prior to the External Distribution as required under Treasury Regulations Section 1.1502-13(d)).

  • 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.

  • The foreign income Tax Return of ForeignCo is a Joint Return because it includes Tax Items of both the External Distributing Business and the External SpinCo Business (and is not required to be filed with respect to Internal SpinCo (or any of its foreign Subsidiaries prior to the External Distribution) or the Thai Subsidiaries, each of which are members of the External SpinCo Group).

  • External SpinCo shall be responsible for preparing and timely filing (i) any Separate Returns that are required to be filed with respect to (A) Internal SpinCo (or any of its Subsidiaries prior to the External Distribution), (B) Safeskin Corporation Thailand Ltd., and (C) Safeskin Medical and Scientific Thailand Ltd.


More Definitions of Internal SpinCo

Internal SpinCo means the new Delaware corporation formed by 3M InterAmerica Inc. pursuant to Domestic Spin-off Step 1 of the Separation Step Plan.
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Internal SpinCo means New GRP Holdco and Arconic Manufacturing.
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Internal SpinCo and “Internal Spincos” have the meanings set forth in Schedule 1.01. “IRS” means the U.S. Internal Revenue Service.
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Internal SpinCo means any of the following entities: HFC Prestige Holding France S.A.S., HFC Prestige International Holding LUXEMBOURG S.à x.x., HFC Prestige International LUXEMBOURG S.à x.x., HFC Prestige International Netherlands Holding B.V., HFC Prestige International Operations Switzerland Sàrl, HFC Prestige International U.S. LLC, HFC Prestige Manufacturing Ireland Limited, HFC Prestige Manufacturing UK Limited, HFC Prestige Products Limited, HFC Prestige Service Germany GmbH, Labocos S.r.l. and Wella (UK) Limited.
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Related to Internal SpinCo

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

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

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

  • 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.

  • Internal Systems means the internal systems of each of the Corporation that are presently used in its Business or operations, including, computer hardware systems, software applications and embedded systems.

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

  • external company means a foreign company that is carrying on business, or non-profit activities, as the case may be, within the Republic, subject to section 23(2);

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

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

  • External Directors means as defined in the Companies Law.

  • external borders means external borders as defined in Article 2(2) of Regulation (EU) 2016/399;

  • SpinCo Entities means the entities, the equity, partnership, membership, limited liability, joint venture or similar interests of which are set forth on Schedule IV under the caption “Joint Ventures and Minority Investments.”

  • 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.

  • external wall means an outer wall of a building even though adjoining to a wall of another building and also means a wall abutting on an interior open space of a building;

  • External Manager means either of the following: (1) A person who is seeking to be, or is, retained by a board or an investment vehicle to manage a portfolio of securities or other assets for compensation, or (2) A person who manages an investment fund and who offers or sells, or has offered or sold, an ownership interest in the investment fund to a board or an investment vehicle.

  • Internal floating roof means a cover or roof in a fixed-roof tank that rests upon or is floated upon, the liquid being contained, and is equipped with a closure seal or seals to close the space between the roof edge and the tank shell.

  • External User means a user of an Online Service that is not an employee, onsite contractor, or onsite agent of Customer or its Affiliates.

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

  • SpinCo Group means (a) prior to the Effective Time, SpinCo and each Person that will be a Subsidiary of SpinCo as of immediately after the Effective Time, including the Transferred Entities, even if, prior to the Effective Time, such Person is not a Subsidiary of SpinCo; and (b) on and after the Effective Time, SpinCo and each Person that is a Subsidiary of SpinCo.

  • Internal control means a process effected by an entity's governing board, management, and other personnel, designed to provide reasonable assurance regarding the achievement of objectives in the following categories:

  • SpinCo Separate Return means any Tax Return of or including any member of the Spinco Group (including any consolidated, combined, or unitary return) that does not include any member of the Remainco Group.

  • Internal combustion engine or ‘engine’ means an energy converter, other than a gas turbine, designed to transform chemical energy (input) into mechanical energy (output) with an internal combustion process; it includes, where they have been installed, the emission control system and the communication interface (hardware and messages) between the engine's electronic control unit(s) and any other powertrain or non-road mobile machinery control unit necessary to comply with Chapters II and III;

  • Wireline means a cable containing one or more electrical conductors which is used to lower and raise logging tools in the well-bore.

  • ITC (this Section2 of the RFP) means the Instructions to Consultants that provides the Consultants with all information needed to prepare their Proposals.

  • 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.

  • NOLs means the Company’s net operating loss carryforwards.