Examples of Millennium Trust Assets in a sentence
Assuming the Millennium Custodial Trust is treated as a liquidating trust, the holders of Millennium Custodial Trust Interests generally should be treated for U.S. federal income tax purposes as the direct owners of an undivided interest in the Millennium Trust Assets.
All parties must treat the transfer of the Millennium Trust Assets to the Millennium Custodial Trust as a transfer of such assets directly to the beneficiaries of the Millennium Custodial Trust, followed by the transfer of such assets by the beneficiaries to the Millennium Custodial Trust.
The holders of Allowed Claims against MCI shall receive the Millennium Custodial Trust Interests, which shall entitle each such holder to its Pro Rata Share of recoveries with respect to the Millennium Trust Assets, including any recovery by MCI from its direct and indirect ownership of the MCI Subsidiaries.
The Millennium Trust Trustee shall determine the fair market value of the Millennium Trust Assets as soon as possible after the Effective Date, and all parties must consistently use this valuation for all U.S. federal income tax purposes.
The Millennium Trust Assets together with the assets of, and Equity Interests in, the MCI Subsidiaries are referred to herein as the “Millennium Trust Chain Assets.” The Debtors anticipate that the existing corporate structure of MCI and the MCI Subsidiaries will remain in place through the Effective Date, except to the extent that the North American Restructuring contemplates changes to the legal status of certain MCI Subsidiaries.
The holders of Allowed Claims against MCI will receive all of the beneficial trust interests in the Millennium Custodial Trust (the “Millennium Custodial Trust Interests”), which will entitle each such holder to its Pro Rata Share of recoveries with respect to the Millennium Trust Assets, including any recovery by MCI from its direct and indirect ownership of the MCI Subsidiaries.
The Millennium Trust Trustee will determine the fair market value of the Millennium Trust Assets as soon as possible after the Effective Date, and all parties must consistently use this valuation for all U.S. federal income tax purposes.
Upon the dissolution of the Trust, and after paying or making reasonable provision for payment of all liabilities of the Trust in accordance with applicable law, the Trustee shall, as expeditiously as is consistent with the conservation and preservation of the Millennium Trust Assets, distribute any remaining assets in the Trust to the Beneficiaries pro rata in accordance with their Millennium Custodial Trust Interests.
Except as otherwise may be expressly provided herein, nothing in this Agreement requires the Trustee to file any accounting, or seek approval of any court, with respect to the administration of the Trust, or as a condition for managing any payment or distribution out of the Millennium Trust Assets.
Any holder of a Millennium Custodial Trust Interest on account of which the amount of cash to be distributed pursuant to any distribution from the Trust is less than $100.00 shall be deemed to have no claim for such distribution against the Trust or the Millennium Trust Assets.