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.
Sample 1Sample 2Sample 3
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.
Sample 1Sample 2
IRS Letter Ruling means the private letter ruling Ref. No. PLR-168887-01 issued by the IRS to Allergan and dated May 15, 2002.
Sample 1Sample 2

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.

  • 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.

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

  • At no time during the Term or Renewal Term shall the Contractor seek an IRS Letter Ruling, SEC No-Action Letter or any other interpretation of Applicable Law by any Governmental Authority specifically relating to the Program independent of the efforts of the Agency to obtain such interpretations and without the express written consent of the Agency, which consent shall not be unreasonably withheld to the extent consistent with the Program.(c) Actions; Expenses.

  • 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 parties agree that the description of the history of "TAPS" and the operative agreements governing "TAPS" as stated in the IRS Letter Ruling are true and correct, and the description therein of the operations of "TAPS" is applicable to the years at issue herein.

  • All of these things require not only your attendance, but your active engagement; students will be expected to make constructive contributions to the tutorial discussion.

  • IRS Letter Ruling 201016033A judicial reformation of a charitable remainder unitrust (CRUT) to eliminate the reference to Section 170(b)(1)(A) in the definition of qualified organization did not cause a trust to fail to qualify as a charitable remainder trust (CRT) within the meaning as distributed to the husband’s charitable foundation.

  • Very truly yours, FIRST CLASS NAVIGATION CORPORATION By: Xxxxxxxxx X.

  • IRS Letter Ruling 200918014Pursuant to the terms of decedent’s will, tangible personal property was bequeathed to decedent’s spouse.


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.
Sample 1

Related to IRS Letter Ruling

  • Private Letter Ruling shall have 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.

  • IRS means the United States Internal Revenue Service.

  • Tax Regulatory Agreement means the Tax Regulatory Agreement dated as of the date hereof by and among the Company, the Issuer and the Trustee.

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

  • 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 means the opinions of Tax Advisors deliverable to OFC in connection with the Transactions.

  • 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 shall have the meaning set forth in Section 6.5(c).

  • 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 of Bond Counsel addressed to the Issuer and the Trustee to the effect that the action proposed to be taken is authorized or permitted by the laws of the Commonwealth and this Indenture and will not, in and of itself, adversely affect any exclusion of interest on the Bonds from gross income of the owners thereof for federal income tax purposes.

  • 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 Xxxxxxxxxx PLLC, with offices located at 0000 Xxxxxxxxxxx Xxxxxx, XX, Xxxxx 000, Xxxxxxxxxx, XX 00000.

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

  • Confirmation Letter means a letter issued by any applicable Rating Agency to the effect that neither (a) the resignation of Provident as Servicer under the Servicing Agreement and appointment of Litton as successor Servicer thereunder, nor (b) the amendments exxxxxxated by this Agreement, will adversely affect the then current ratings on the Certificates then being rated.