IRS Letter Ruling definition

IRS Letter Ruling means an IRS private letter ruling, dated August 2, 2002, setting forth IRS rulings regarding certain Tax consequences of the Distribution and certain related transactions, together with any supplemental private letter rulings issued with respect thereto.
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IRS Letter Ruling means a private letter ruling from the IRS ruling that, among other things, the Merger will qualify as a reorganization under Section 368(a) of the Code.
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IRS Letter Ruling means the private letter ruling Ref. No. PLR-168887-01 issued by the IRS to Allergan and dated May 15, 2002.
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Examples of IRS Letter Ruling in a sentence

  • The tax regulations do not specifically provide a formal method for computing what this portion is; however, IRS Letter Ruling 8213102 indicates a method of calculating a medical expense percentage by using the ratio of medical expenses to all expenses of the Community.

  • Also, Parent will pay all the fees, costs and expenses associated with obtaining the IRS Letter Ruling.

  • IRS Letter Ruling 200925008A decedent’s will created two (2) marital trusts (A & B).

  • Other than with respect to the IRS Letter Ruling, neither the Company nor any Subsidiary of the Company has a private letter ruling, technical advice, application for a change of any method of accounting, or other similar request presently pending with any taxing authority.

  • IRS Letter Ruling 201021048; 6/7/2010The IRS has privately ruled that the treatment of a taxpayer and his domestic partner’s earnings as community property did not result in a transfer of property between the couple for purposes of the federal gift tax.

  • IRS Letter Ruling 20103202; 9/10/2010The IRS has held that a nonresident alien donor’s transfer of the naked title of her shares in a holding company to her U.S. resident alien daughter and U.S. grandchildren did not subject the donor to gift or generation-­‐skipping (GST) tax.

  • IRS Letter Ruling 201006005The reformation of a trust to conform to the intent of the trustor at the time of execution of the trust, relating back to the date that the instrument was executed, did not cause the trust to be included in the gross estate of the trustor’s son under Section 2041.

  • IRS Letter Ruling 200901023In Private Letter Ruling 200901023, the Internal Revenue Service held that a wife’s lifetime and testamentary transfers to a foreign trust to manage and distribute her deceased husband’s works of art would qualify for the estate and gift tax charitable deductions.

  • The parties will cooperate with each other in a commercially reasonable manner in order that the conditions to the obligations of the Agency and the Contractor contained in Section 10 are satisfied and the duties and obligations of the parties hereunder may be effectively, efficiently and promptly discharged.(b) IRS Letter Ruling; SEC No-Action Letter.

  • The Contractor will pay the fees and disbursements of its counsel in connection with the preparation of the requests for and efforts to obtain the IRS Letter Ruling and/or SEC No-Action Letter, as applicable.(d) Further Cooperation.


More Definitions of IRS Letter Ruling

IRS Letter Ruling means the private letter ruling Xxx Xx. XXX-x00000-00 issued by the IRS to Allergan and dated May 15, 2002.
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Related to IRS Letter Ruling

  • Private Letter Ruling has the meaning set forth in the recitals.

  • IRS Ruling shall have the meaning set forth in the Recitals.

  • Tax Ruling as used in this Agreement, shall mean a written ruling of a taxing authority relating to Taxes. "Closing Agreement", as used in this Agreement, shall mean a written and legally binding agreement with a taxing authority relating to Taxes.

  • Supplemental Ruling means (i) any ruling (other than the Ruling) issued by the IRS in connection with a Distribution, and (ii) any similar ruling issued by any other Taxing Authority addressing the application of a provision of the laws of another jurisdiction to a Distribution.

  • closing agreement as described in Section 7121 of the Code (or any corresponding or similar provision of state, local or foreign income Tax law) executed on or prior to the Closing Date; (iii) installment sale or open transaction disposition made on or prior to the Closing Date; or (iv) prepaid amount received on or prior to the Closing Date;

  • Ruling Request means any letter filed by Parent with the IRS requesting a ruling regarding certain tax consequences of the Transactions (including all attachments, exhibits, and other materials submitted with such ruling request letter) and any amendment or supplement to such ruling request letter.

  • advance ruling means a decision provided by the Authority or the Appellate Authority to an applicant on matters or on questions specified in sub-section (2) of section 97 or sub-section (1) of section 100, in relation to the supply of goods or services or both being undertaken or proposed to be undertaken by the applicant;

  • IRS means the United States Internal Revenue Service.

  • Tax Regulatory Agreement means the Tax Regulatory Agreement, dated as of the date of initial issuance and delivery of the Bonds, among the Authority, the Borrower and the Trustee, and any amendments and supplements thereto.

  • Tax Counsel shall have the meaning set forth in Section 6.2 hereof.

  • Advance Ruling Certificate means an advance ruling certificate issued by the Commissioner of Competition pursuant to section 102 of the Competition Act with respect to the transactions contemplated by this Agreement.

  • Tax Opinion means, with respect to any action, an Opinion of Counsel to the effect that, for federal income tax purposes, (a) such action will not cause the Notes of any outstanding class of Notes that were characterized as debt at the time of their issuance to be characterized as other than debt, (b) such action will not cause the Trust to be deemed to be an association (or publicly traded partnership) taxable as a corporation and (c) such action will not cause or constitute an event in which gain or loss would be recognized by any Holder.

  • Tax Opinions mean certain Tax opinions and supporting memoranda rendered by XxXxxxxxx to Tyco or any of its Affiliates in connection with the Plan of Separation.

  • Tax Opinions/Rulings means (i) any Ruling and (ii) any opinion of a Tax Advisor relating to the Transactions, including those issued on the Distribution Date or to allow a party to take actions otherwise prohibited under Section 4.03(a) of this Agreement.

  • Alternative Acquisition Agreement has the meaning set forth in Section 5.3(d).

  • Tax Matters Agreement means the Tax Matters Agreement to be entered into by and between Parent and SpinCo or any members of their respective Groups in connection with the Separation, the Distribution or the other transactions contemplated by this Agreement, as it may be amended from time to time.

  • Ruling Documents means the Ruling and the Ruling Request.

  • Post-Closing Agreement shall have the meaning set forth in Section 8.9.

  • Tax Certification Forms means any forms or other documentation as may be issued or required by a Tax Authority or by us from time to time to confirm your tax status [or the tax status of a Connected Person].

  • Representation Letters means the representation letters and any other materials (including, without limitation, a Ruling Request and any related supplemental submissions to the IRS) delivered or deliverable by, or on behalf of, Parent, SpinCo and others in connection with the rendering by Tax Advisors and/or the issuance by the IRS of the Tax Opinions/Rulings.

  • Favorable Opinion of Bond Counsel means an opinion or opinions of nationally recognized bond counsel to the effect that the action proposed to be taken is authorized or permitted by the Certificate and will not adversely affect the exclusion of interest on the Bonds from gross income for purposes of federal income taxation.

  • Sponsor Letter Agreement has the meaning set forth in the recitals to this Agreement.

  • Company Acquisition Agreement has the meaning set forth in Section 5.04(a).

  • Transition Agreement has the meaning set forth in Section 12.8.1.

  • Company Counsel means Ellenoff Gxxxxxxx & Schole LLP, with offices located at 1000 Xxxxxx xx xxx Xxxxxxxx, Xxx Xxxx, Xxx Xxxx 00000-0000.

  • Tax Allocation Agreement means the Tax Allocation Agreement between Corporation and New D&B.