Examples of Multicare Group in a sentence
As a result, the stock value of Reorganized Genesis attributable to its ownership of Reorganized Multicare will not be able to be taken into account in determining the annual limitation applicable to the Genesis Group to the extent that the value of Reorganized Multicare is taken into account in determining the annual limitation applicable to the Multicare Group (and possibly will only be useable by Genesis if an affirmative election is made by Multicare permitting it to do so).
Consequences to the Debtors The Genesis Debtors, on the one hand (the "Genesis Group"), and the Multicare Debtors, on the other hand (the "Multicare Group"), each file a separate consolidated federal income tax return, excluding those Debtors that are treated as partnerships for federal income tax purposes.
Moreover, at or about the end of 1999, the Genesis Group and the Multicare Group each underwent an "ownership change" within the meaning of Section 382 of the Tax Code.
For a corporation in bankruptcy and, presumably, where, as in the case of the Genesis Group and the Multicare Group, the common parent is in bankruptcy and undergoes the ownership change pursuant to a confirmed plan, the stock value generally is determined immediately after (rather than before) the ownership change, and some of the adjustments that ordinarily would apply do not apply.
The Debtors anticipate that an ownership change of the Genesis Group and the Multicare Group will occur upon implementation of the Plan.
Because the creditors of the Multicare Debtors (even though partially overlapping with those of the Genesis Debtors) will not receive 50% or more of the stock of Reorganized Genesis in exchange for their claims against the Multicare Debtors, this exception will not apply to the Multicare Group.
It is currently unclear whether the Genesis Group or the Multicare Group will be in a net unrealized built-in loss position and/or a net unrealized built-in gain position as of the Effective Date.
However, neither Genesis nor Multicare believes that deductibility of future depreciation or amortization deductions of the Genesis Debtors or the Multicare Debtors, respectively, would be significantly impaired, even if the Genesis or Multicare Group (as the case may be) were determined to be in a net unrealized built-in loss position.
For purposes of calculating the financial projections of Reorganized Genesis it has been assumed that no consolidated NOLs or NOL carryforwards of the Genesis Group or the Multicare Group will survive the reorganization and that any reduction in the tax basis in depreciable or amortizable assets of the Debtors would be insignificant.
No Loan Party nor any member of the Multicare Group is in material violation of the rights of others with respect to intellectual property.