Private Letter Rulings definition

Private Letter Rulings means, collectively, the Tax-Free Split-Off Ruling, the Tax-Free Reorganization Ruling, the Tax-Free Debt Exchange Ruling and the Section 355(d) Ruling.
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Private Letter Rulings means the private letter rulings obtained in the name of certain Members and former members from the IRS dated on or about August 13, 2014 in accordance with Section 7.5 of each Purchase Agreement. "Producer Suspension Event" has the meaning given such term in the Refined Coal Sale Agreement. "Producer Suspension Event Notice" has the meaning given such term in the Refined Coal Sale Agreement. "Producer Suspension Remedial Actions" has the meaning set forth in Section 8.2(b). "Proiect Documents" means (a) the Refined Coal Sale Agreement, (b) the Coal Yard Services Agreement, (c) the Feedstock Coal Purchase Agreement, (d) the Site License 11
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Private Letter Rulings has the meaning set forth in Section 5.22.
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Examples of Private Letter Rulings in a sentence

  • We will follow the position you request, provided it is consistent with our understanding of the Internal Revenue Code (“IRC”), tax regulations, Revenue Rulings, Revenue Procedures, Private Letter Rulings and court cases.

  • Tax reference materials include but are not limited to, the Internal Revenue Code (“IRC”), tax regulations, Revenue Rulings, Revenue Procedures, Private Letter Rulings, court cases, and similar state and local guidance.

  • Tax reference materials include, but are not limited to, the Internal Revenue Code (“IRC”), tax regulations, Revenue Rulings, Revenue Procedures, Private Letter Rulings and court decisions.

  • WIN and Holdings shall be responsible in the first instance for the preparation of all memoranda, ruling requests, correspondence and other submissions to the IRS in connection with obtaining the Private Letter Rulings; provided that the WCAS Subs shall be responsible in the first instance for the preparation of all memoranda, ruling requests, correspondence and other submissions to the IRS that relate principally to those portions of the Private Letter Rulings that pertain principally to the WCAS Subs.

  • The IRS Private Letter Rulings addressed to RVI and DSW with respect to the Merger, including any supplements thereto (“IRS Rulings”) shall continue to remain in full force and effect.

  • G.4.1 Continuing (permanent) staff are entitled to five weeks annual leave to be taken in accordance with the ▇▇▇▇▇▇▇▇ ▇▇▇ ▇▇▇▇ and its amendments.

  • Each of WIN and the WCAS Subs shall have the right to participate fully in the process of obtaining the Private Letter Rulings, including attending meetings and participating in conference calls with the IRS.

  • The Association shall ensure that the Trust applies for and secures tax exempt status, including an IRS determination letter, pursuant to Internal Revenue Code provision 501(c)(9) and all other applicable laws and regulations; and the Association shall procure an appropriate Private Letter Ruling(s) (PLR) authorizing the funding of the trust on a tax-favored basis (i.e., that the salary and sick/vacation leave contributions will be made to the Trust on a pre-tax basis) prior to its establishment.

  • WIN shall, and WIN shall cause Holdings and the Division Subsidiaries to, and the WCAS Subs shall, use their respective reasonable best efforts to obtain the Private Letter Rulings, substantially on the terms set forth in, and otherwise in accordance with, the Tax Sharing Agreement, as soon as practicable after the date of this Agreement.

  • Each of Hilton and Company shall use its reasonable best efforts and cooperate with the other party and to obtain from the Service or tax counsel, as the case may be, the Private Letter Rulings or tax opinions, as the case may be, contemplated by Section 8.1(d) and 8.1(e) of this Agreement.