Private Letter Ruling definition

Private Letter Ruling shall have the meaning set forth in the Recitals.

Private Letter Ruling means (a) any private letter ruling issued by the IRS in connection with any of the Spin-Off-Related Transactions or (b) any similar ruling issued by any other Tax Authority in connection with any of the Spin-Off-Related Transactions.

Private Letter Ruling means, in the event of a Distribution, (a) any private letter ruling issued by the IRS in connection with the Distribution or (b) any similar ruling issued by any other Tax Authority in connection with the Distribution.

Examples of Private Letter Ruling in a sentence

• Generally, in order to receive this relief you must apply for a Private Letter Ruling accompanied by the applicable user fee.

• Cost Sharing contributions shall be made on a pre-tax basis unless and until a Private Letter Ruling (PLR) by the Internal Revenue Service is issued to the City by the Internal Revenue Service designating that the payments must be post-tax.

• The Funds' multiple class program became effective on November 14, 1994 pursuant to: (i) Board approval of the program received on June 28, 1994; (ii) an SEC Exemptive Order dated June 21, 1994; and (iii) an IRS Private Letter Ruling dated May 10, 1994(2).

• RD856 (Published 2022) - Return to Work Provisions Governing Virginia Retirement System (VRS) Retirees – December 15, 2022.Internal Revenue Service (IRS) guidance under Internal Revenue Code (IRC) § 410, as cited in Private Letter Ruling 201147038, suggests that a one-year period without performing service might be considered a safe harbor to establish severance from employment prior to a retiree returning to work for a plan employer.

• The Division may require an IRS Private Letter Ruling for projects that target a specific segment of the population.

More Definitions of Private Letter Ruling

Private Letter Ruling means a private letter ruling issued by the IRS addressing the qualification of the Contribution, the Reorganized TCEH Conversion, and the Distribution as a “reorganization” within the meaning of Sections 368(a)(1)(G), 355 and 356 of the Internal Revenue Code and certain other matters.

Private Letter Ruling means the private letter ruling issued by the IRS to EFH Corp. on July 28, 2016.

Private Letter Ruling means the private letter ruling issued to UTC on December 13, 2019 in response to the IRS Ruling Request.

Private Letter Ruling shall have the meaning set forth in Section 3.01(a).

Private Letter Ruling has the meaning set forth in the Separation Agreement.

Private Letter Ruling means the private letter ruling issued by the Service to FIS that addresses, inter alia, the tax consequences of the Contribution, Distribution, and Debt Exchange.

Private Letter Ruling has the meaning set forth in Section 2.9(b).