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 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.

Examples of Opinion of Tax Counsel in a sentence

• The Company reserves the right, however, to make any investment of such amounts permitted by Illinois law, if, when and to the extent that Section 148 of the Internal Revenue Code of 1986, as amended, or regulations promulgated under it shall be repealed or relaxed or shall be held void by final judgment of a court of competent jurisdiction, but only upon receipt of a Favorable Opinion of Tax Counsel with respect to such investment.

• No such assignment will be made unless the Borrower causes there to be delivered to the Purchaser and the Issuer an Opinion of Tax Counsel to the effect that such assignment will not cause interest on the Bond to be includable in the gross income of the owners thereof for federal income tax purposes.

• I feel truly awful that Mia is injured, and I hope nothing like this ever happens to any other athlete, anywhere.

• Wadham School is required to have in place a Conflict of Interest policy that enables us to identify, manage and mitigate any potential conflicts of interest.

• Notwithstanding anything in this Funding Loan Agreement to the contrary, no additional amounts of the Funding Loan may be drawn down and funded hereunder after December 31, 2025; provided, however, that upon the delivery of a Favorable Opinion of Tax Counsel to the Governmental Lender, the Fiscal Agent and the Funding Lender such date may be changed to a later date as specified in such Favorable Opinion of Tax Counsel.

More Definitions of Opinion of Tax Counsel

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 one or more written opinions of an attorney or Ñrm 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 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 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.

Opinion of Tax Counsel means a legal opinion reasonably acceptable to Buyer from Tax Counsel that the Project will qualify for the [Full ITC].