Opinion of Tax Counsel definition

Opinion of Tax Counsel means an Opinion of Counsel by counsel of nationally recognized standing in matters relating to the exclusion of interest from gross income on obligations issued by or on behalf of states and their political subdivisions.

Opinion of Tax Counsel means a legal opinion from ITC Tax Counsel substantially in the form of Exhibit Q.

Opinion of Tax Counsel means an Opinion of Counsel by counsel of nationally recognized standing in matters relating to the exclusion of interest from gross income on obligations issued by states and their political subdivisions or agencies.

Examples of Opinion of Tax Counsel in a sentence

• The notice must be accompanied by a Favorable Opinion of Tax Counsel, except as described below.

• Notwithstanding anything in this Indenture to the contrary, the Company must deliver a Favorable Opinion of Tax Counsel whenever there is a change from a period during which the interest rate on the Bonds is set at intervals of 365 days or less to a period during which the interest rate on the Bonds is set at intervals in excess of 365 days, or vice versa.

• If such Favorable Opinion of Tax Counsel has not been delivered, the Bonds shall remain in a Long-Term Interest Rate Period with an interest rate equal to the interest rate for the prior Long-Term Interest Rate Period and with a duration equal to the prior Long-Term Interest Rate Period (or, if earlier, a Long-Term Interest Rate Period ending on the day before the Maturity Date for such Bond).

• Notwithstanding any provision of this Section 2.02, no change shall be made in the interest rate determination method at the direction of the Company pursuant to Section 2.02(b)(1) hereof if the Trustee shall receive written notice prior to such change that the Favorable Opinion of Tax Counsel required under Section 2.02(b)(1) or Section 2.02(a)(5) or, if applicable, the Opinion of Tax Counsel required by Section 2.02(b)(2)(ii), has been rescinded.

• Except in the case of the rescission of the Favorable Opinion of Tax Counsel described in Section 2.02(e), if the Company's notice complies with this paragraph, the interest rate on the Bonds will be payable at the new rate on the effective date specified in the notice until there is another change as provided in this Section.

More Definitions of Opinion of Tax Counsel

Opinion of Tax Counsel means one or more written opinions of an attorney or firm of attorneys duly admitted to the practice of law before the highest court of any state of the United States of America and experienced in matters pertaining to the tax-exempt status of interest on state and local obligations, as well as to the status of interests in trusts, partnerships and other structures containing such obligations, which counsel is satisfactory to the Administrator and Xxxxxxx Mac and which opinion is addressed to the Administrator and Xxxxxxx Mac, and is in form and in substance satisfactory to the Administrator and Xxxxxxx Mac.

Opinion of Tax Counsel means an opinion of counsel, acceptable to the Board, nationally recognized for its experience in matters relating to the tax exemption of interest on obligations issued by states and their political subdivisions.

Opinion of Tax Counsel means an opinion of the Tax Counsel (which need not be unqualified) which sets forth (A) the “base amount” within the meaning of Section 280G of the Code; (B) the aggregate present value of the payments in the nature of compensation to the Executive as prescribed in Section 280G(b)(2)(A)(ii) of the Code; and (C) the amount and present value of any “excess parachute payment” within the meaning of Section 280G(b)(1) of the Code, unless, in the reasonable opinion of the Tax Counsel, such excess parachute payments represent reasonable compensation for services actually rendered within the meaning of Section 280G(b)(4)(B) of the Code, or are not otherwise subject to the Excise Tax. For purposes of such opinion, the value of any non-cash benefits or any deferred payment or benefit shall be determined by Tax Counsel in accordance with the principles of Section 280G of the Code, which determination and the method of its determination shall be evidenced in a certificate of such Tax Counsel addressed to the Company and the Executive. In providing the opinion or determining the value of any non-cash benefit or deferred payment or benefit, Tax Counsel may rely on the advice of a firm of recognized executive compensation consultants, appraisers, actuaries, or accountants, as to the value or reasonableness of any item of compensation to be received by the Executive. The Opinion of Tax Counsel shall be dated as of the date of termination of the Executive’s employment and addressed to the Company and the Executive and shall be binding upon the Company and the Executive.

Opinion of Tax Counsel means one or more written opinions of an attorney or firm of attorneys duly admitted to the practice of law before the highest court of any state of the United States of America and experienced in matters pertaining to the tax-exempt status of interest on state and local obligations, as well as to the status of interests in trusts, partnerships and other structures containing such obligations, which counsel is satisfactory to the Administrator and Freddie Mac and which opinion is addressed to the Administrator and Freddie Mac, and is in form and in substance satisfactory to the Administrator and Freddie Mac.

Opinion of Tax Counsel means an opinion of independent nationally recognized tax counsel experienced in the matter that is the subject of the opinion.

Opinion of Tax Counsel means the written opinion of counsel rendered by an independent law firm with generally recognized experience in such matters.

Opinion of Tax Counsel means an Opinion of Counsel experienced in matters relating to the tax exemption of interest on obligations issued by states and their political subdivisions.