IRS Private Letter Ruling definition

IRS Private Letter Ruling means the private letter ruling issued by the IRS in response to the Application for Ruling.
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IRS Private Letter Ruling has the meaning set forth in the Tax Sharing Agreement.
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IRS Private Letter Ruling means the federal income tax rulings issued to Old Viacom on November 22, 2005 by the IRS in connection with the Separation Transactions.
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Examples of IRS Private Letter Ruling in a sentence

  • The Funds' multiple class program became effective on November 14, 1994 pursuant to: (i) Board approval of the program received on June 28, 1994; (ii) an SEC Exemptive Order dated June 21, 1994; and (iii) an IRS Private Letter Ruling dated May 10, 1994(2).

  • The Division may require an IRS Private Letter Ruling for projects that target a specific segment of the population.

  • Within seven Days after receipt of any IRS Private Letter Ruling, the Trustee shall provide a copy to the United States (pursuant to subparagraph 6.0.1) and the known Beneficiaries (pursuant to the secure internet-based communication established in Paragraph 6.0).

  • General Public Use Requirements.The Division may require an IRS Private Letter Ruling for projects that target a specific segment of the population.

  • An IRS Private Letter Ruling may be required by the Division for projects that target a specific segment of the population to ensure compliance with the General Use requirement.

  • In order to further the purposes of IRS Private Letter Ruling 112002-11, notwithstanding anything expressed or implied to the contrary in this Agreement, nothing outside of this Section 6.21 or Section 6.23 shall confer upon the Liquidity Provider any rights to a redemption of Purchased VRDP Shares (other than the rights provided to Holders under the Articles Supplementary).

  • To the extent there is a Tax Item relating to the Transactions which is not covered by the IRS Private Letter Ruling or the Tax Opinion, the tax treatment of such Tax Items on a Tax Return shall be determined by the Responsible Company with respect to such Tax Return, provided (i) there is substantial authority for such tax treatment, and (ii) such tax treatment is not inconsistent with the tax treatment contemplated in the IRS Private Letter Ruling or the Tax Opinion.

  • ICN currently intends, following the consummation of the Initial Public Offering, to complete the Distribution as promptly as practicable after receipt of an IRS Private Letter Ruling.

  • An IRS Private Letter Ruling issued 6/16/95, allowed a unit to be occupied by a security officer (a/k/a courtesy officer) if it was reasonably required by the development.

  • The tax treatment reported on any Tax Return of Tax Items relating to the Transaction shall be consistent with the treatment of such item in the IRS Private Letter Ruling.


More Definitions of IRS Private Letter Ruling

IRS Private Letter Ruling means the private letter ruling issued to VSI by the IRS, dated November 23, 2020.
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IRS Private Letter Ruling means a private letter ruling issued by the IRS in response to the Application for Ruling that provides that the Distribution will qualify under Section 355 and related provisions of the Code as a tax-free spin-off, and that no income, gain or loss will be recognized for U.S. federal income tax purposes by ICN, the stockholders or former stockholders of ICN, or any ICN Affiliate with respect to the Distribution.
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IRS Private Letter Ruling means the letter dated November 16, 2004 from Mxxxxxx X. Xxxxxx, Senior Technician Reviewer in the Office of Associate Chief Counsel of the IRS, to Bxxxxxx X. Xxxxxxxxxx, Vice President, Finance and CFO of Modine (the "Original Letter Ruling"), the original request for such letter ruling and all related documentation submitted to the IRS in connection with such request, and the supplemental letter ruling issued by the IRS and any documentation submitted in connection with the request for such supplemental letter ruling (the "Supplemental Ruling").
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IRS Private Letter Ruling means the supplemental private letter ruling from the United States Internal Revenue Service issued in connection with the Distribution on July 14, 2003, and, to the extent not superceded by such private letter ruling, the private letter ruling from the United States Internal Revenue Service issued in connection with the Distribution on September 30, 2002
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Related to IRS Private Letter Ruling

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

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

  • 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.

  • 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;

  • 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.

  • 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.

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

  • 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;

  • 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.

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

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

  • 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.

  • Company U.S. Counsel means Hxxxxx and Bxxxx, LLP, with offices located at 30 Xxxxxxxxxxx Xxxxx, 00xx Xxxxx, Xxx Xxxx, Xxx Xxxx 00000.

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

  • 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.

  • Closing protection letter means an agreement by the division to indemnify a lender or owner or both for loss caused by a division closer’s theft of settlement funds or failure to comply with written closing instructions relating to title certificate coverage when agreed to by the division closer.

  • Implementation Letter means the letter of even date herewith from the Borrower to the Bank setting forth the Project monitoring indicators;

  • 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 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].

  • Tax Compliance Agreement means the Federal Tax Certificate, Tax Compliance Agreement, Arbitrage Agreement, or other written certification or agreement of the Issuer setting out representations and covenants for satisfying the post-issuance tax compliance requirements for the Tax-Exempt Bonds.

  • Post Closing Letter is that certain Post Closing Letter dated as of the Effective Date by and between Collateral Agent and Borrower.

  • Public-private partnership agreement means an agreement

  • 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.

  • 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.

  • 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.

  • Definitive Acquisition Agreement means any agreement entered into by the Company that is conditioned on the approval by the holders of not less than a majority of the outstanding Common Shares of the Company and is with respect to (i) a share exchange, one-step merger, tender offer and second-step merger, consolidation, recapitalization, reorganization, business combination or similar transaction involving the Company, or (ii) the acquisition, directly or indirectly, of assets or earning power aggregating 50% or more of the consolidated assets or earning power of the Company and its Subsidiaries (taken as a whole).