Parent Reorganization Tax Opinion Representation Letter definition

Parent Reorganization Tax Opinion Representation Letter means the representation letter substantially in the form of Exhibit F, with such changes, updates or refinements, agreed to by Parent, the Company, Parent Tax Counsel and Company Reorganization Tax Counsel, as may be reasonably necessary to reflect any changes in, or clarifications of, facts prior to the Closing, to be executed by Parent, and dated and effective as of the Closing Date (and if applicable, as of the date of any Reorganization Tax Opinions to be delivered in connection with the Registration Statement), delivered to each of the tax counsel providing the Reorganization Tax Opinions as a condition to, and in connection with, the issuance of the Reorganization Tax Opinions.
Parent Reorganization Tax Opinion Representation Letter means the representation letter substantially in the form of Exhibit D, with such changes, updates or refinements, agreed to by Parent, the Company, Parent Tax Counsel and Company Reorganization Tax Counsel, as may be necessary to reflect any changes in, or clarifications of, facts prior to the Closing, to be executed by Parent, and dated and effective as of the Closing Date (and if applicable, as of the date of any Reorganization Tax Opinions to be delivered in connection with the Registration Statement), delivered to each of the tax counsel providing the Reorganization Tax Opinions as a condition to, and in connection with, the issuance of the Reorganization Tax Opinions.
Parent Reorganization Tax Opinion Representation Letter means the representation letter executed by Pxxxxx, and dated and effective as of the date hereof, delivered to Company Tax Counsel as a condition to, and in connection with, the issuance of the Company Reorganization Tax Opinion.

Related to Parent Reorganization Tax Opinion Representation Letter

  • Tax Opinions mean certain Tax opinions and supporting memoranda rendered by Xxxxxxx to ITT or any of its Affiliates in connection with the Plan of Separation.

  • Closing protection letter means an agreement by the division to indemnify a lender or owner or both for loss caused by a division closer’s theft of settlement funds or failure to comply with written closing instructions relating to title certificate coverage when agreed to by the division closer.