New UPC definition
Examples of New UPC in a sentence
The Plan shall have been confirmed by the Bankruptcy Court on substantially the terms set forth in the Second Amended Chapter 11 Plan of Reorganization Jointly Proposed by Seller and New UPC, Inc., dated January 7, 2003 and filed with the United States Bankruptcy Court on January 9, 2003.
Any holder of an Allowed UPC Polska Note Claim (other than Allowed Telecom Owned UPC Polska Note Claims) that has a tax basis in any New UPC Polska Notes received that is less than the issue price of such notes generally will be subject to the market discount rules of the Tax Code (unless such difference is less than a statutorily defined de minimis amount).
Programme at the Receiving Organisation) As already indicated at the beginning of these guidelines, this part of the Learning Agreement is optional and may be used as a record to keep track of the changes made to the initial training project.
Any market discount will be considered to accrue on a straight-line basis during the period from the date of acquisition of such New UPC Polska Notes to the maturity date of the notes, unless the holder irrevocably elects to compute the accrual on a constant yield basis.
If such an election to amortize bond premium is not made, a holder will receive a tax benefit from the premium only in computing such holder's gain or loss upon the sale or other taxable disposition of the New UPC Polska Note, or upon the full or partial payment of principal.
If the New UPC Polska Notes are issued with OID, and a holder of a Claim has a tax basis in any of the New UPC Polska Notes received that exceeds the issue price of such note, but is less than or equal to the sum of all amounts payable on such notes other than payments of qualified stated interest (i.e., an "acquisition premium"), the amount of OID includable in the holder's gross income generally is reduced in each period in proportion to the percentage of the OID represented by the excess basis.
For a discussion of the tax consequences of any Claims for accrued OID, see the discussion titled “Distributions in Discharge of Accrued OID,” below.Any gain as described above on the exchange of the UPC Polska Note Claims for the New UPC Polska Notes may be subject to the installment sale rules, which may result in the deferral of gain, if any, recognized by holders on the exchange.
Conversely, UPC Polska believes the New UPC Polska Notes - which will have a maturity of three years – probably will not constitute “securities” for such purposes.
Such an election may not be revoked without the consent of the IRS.If the New UPC Polska Notes are issued with OID, and a holder has a tax basis in any of the New UPC Polska Notes received that exceeds the sum of all amounts payable on such notes other than payments of qualified stated interest (i.e., a “bond premium”), the holder will not include any of the OID in income.
If such bond premium is amortized, the amount of qualified stated interest on any New UPC Polska Note that must be included in the holder's gross income for each period ending on an interest payment date or at the maturity date, as the case may be, will (except as Treasury Regulations may otherwise provide) be reduced by the portion of bond premium allocable to such period based on the note's yield to maturity.