Letter ruling definition

Letter ruling means a formal document issued by the department to a specific taxpayer on a specific tax matter related to a future transaction. A taxpayer shall request a letter ruling on a form and in a manner prescribed by the department.

Letter ruling means a written interpretation of law to a

Letter ruling means a written interpretation of law to a specific set of facts provided by the applicant requesting a letter ruling.

Examples of Letter ruling in a sentence

• Letter ruling" means a formal document issued by the department to a specific taxpayer on a specific tax matter related to a future transaction.

• If the extension request is denied, there is no right of appeal.(3) Letter ruling request closed if the taxpayer does not submit additional informa- tion.

• The amount of surviving corpora- tion stock that would be treated as purchased (on the date the surviving corporation shareholders purchased their surviving corporation stock) if the controlling corporation acquired the stock of the surviving corporation in a transaction in which the basis in the surviving corporation’s stock was determined under section 362(b) (see§§ 1.358–6(c)(2)(ii)(B) and 1.1502–30(b)).(ii) Letter ruling and closing agreement.

• The foregoing sentence shall not apply, and the limitation shall be that provided by the Code or the Internal Revenue Service, as the case may be, if such annual limit is changed or eliminated by (a) amendment of the Code or (b) issuance by the Internal Revenue Service of (i) a Revenue ruling, (ii) a Private Letter ruling to any of the Company, any Optionee, or any legatee, personal representative, or distributee of any Optionee, or (iii) regulations.

• If you have further questions concerning this Private Letter ruling, you may contact me at (217) 782-2844.

More Definitions of Letter ruling

Letter ruling means a private letter ruling received from the Internal Revenue Service to the effect that, among other things, the Distribution will qualify as a tax-free distribution for federal income tax purposes under Section 355 of the Code.

Letter ruling means a written interpretation of law by the

Letter ruling means a written interpretation of law to a specific set of facts provided

Letter ruling means a written interpretation of law to a specific set of facts provided by an applicant requesting the written interpretation from the Arkansas Economic Development Commission;

Letter ruling means the advance letter rulings expected to be issued by the IRS to Methode regarding certain U.S. federal income tax consequences of the Distribution and other related transactions and any supplemental letter rulings issued by the IRS with respect thereto; provided, however, that the requesting party complied with the provisions of the Tax Sharing Agreement relating to requests for supplemental rulings and obtained any necessary approval of the other party thereto.

Letter ruling means a private letter ruling from the Internal Revenue Service in form and substance satisfactory to Allergan (in its sole discretion), which ruling shall not have been revoked as of the Distribution Date, to the effect that (i) the transfer by the Allergan Group to the AMO Group of the AMO Assets, subject to Liabilities and AMO's assumption of liabilities, followed by the Distribution, will qualify as a reorganization under Sections 368(a)(1)(D) and 355 of the Code; (ii) no gain or loss will be recognized by Allergan on its transfer of the AMO Assets and AMO Liabilities to AMO (iii) no gain or loss will be recognized by AMO on its receipt and assumption of the AMO Assets and AMO Liabilities from Allergan in exchange for the issuance of AMO common stock and the Distributable Cash; and (iv) no gain or loss will be recognized by (and no amount will otherwise be included in the income of) the stockholders of Allergan upon their receipt of AMO common stock pursuant to the Distribution (except in respect of cash received in lieu of fractional shares of AMO).

Letter ruling means the advance letter ruling expected to be issued by the IRS to Methode setting forth certain Federal Income Tax consequences of the Reorganization, and any supplemental or additional letter rulings that may be issued by the IRS to any of the Parties or their Affiliates with respect to the Reorganization or any part thereof in response to a ruling request by Methode or Stratos that received Stratos Sole Discretion Consent or Methode Sole Discretion Consent, respectively.