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

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.

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

Examples of Private Letter Ruling in a sentence

If either the Internal Revenue Service issues guidance acceptable to both parties, or the County receives a Private Letter Ruling from the IRS, that protects the County and DSA members hired prior to January 1, 2013, from additional tax liability, DSA members will have the opportunity to elect new retirement tiers pursuant to Government Code section 31484.9.

More Definitions of Private Letter Ruling

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 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 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 shall have 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 11.06(a).