Examples of Public Unitholder in a sentence
In the event of the exercise by Purchaser Sub of its Call Right, each Public Unitholder will be obligated to sell all the Public Units which are subject to the Call Right held by such Public Unitholder to Purchaser Sub on the Effective Date on payment by, or on behalf of Purchaser Sub, to such Public Unitholder of the BAM Share Consideration and/or New Preferred Unit Share Consideration, as applicable, for each such Public Unit.
The tax liability of a CCR Public Unitholder as a result of the Merger could be more than expected.
In such case, as a result of the Merger, a CCR Public Unitholder will recognize gain or loss for U.S. federal income tax purposes equal to the difference between such unitholder’s amount realized and the unitholder’s adjusted tax basis in the CCR Common Units, which will be increased by the U.S. Holder’s share of certain items related to business interest not yet deductible by such U.S. Holder due to applicable limitations on the deductibility of such business interest.
The Merger will be a taxable transaction and, in such case, the resulting tax liability of a CCR Public Unitholder, if any, will depend on the unitholder’s particular situation.
The U.S. federal income tax consequences of the Merger to a CCR Public Unitholder will depend on such unitholder’s own personal tax situation.
The amount of gain or loss recognized by each CCR Public Unitholder in the Merger will vary depending on each unitholder’s particular situation, including the value of the shares of CEIX Common Stock received by each unitholder in the Merger, the adjusted tax basis in the CCR Common Units exchanged by each unitholder in the Merger, and the amount of any suspended passive losses that may be available to a particular unitholder to offset a portion of the gain recognized by the unitholder.
Consequently, a CCR Public Unitholder may recognize both ordinary income and capital loss upon the exchange of CCR Common Units in the Merger.
A pro rata distribution of cash by CCR to a CCR Public Unitholder who is a U.S. Holder is generally not taxable for U.S. federal income tax purposes unless the amount of cash distributed is in excess of the CCR Public Unitholder’s adjusted tax basis in its CCR Common Units.
Because the value of any shares of CEIX Common Stock received in the Merger will not be known until the Effective Time, a CCR Public Unitholder will not be able to determine its amount realized, and therefore its taxable gain or loss, until such time.
No fractional shares of CEIX Common Stock will be issued in the Merger; instead, all fractional shares of CEIX Common Stock to which a CCR Public Unitholder otherwise would have been entitled will be aggregated and the resulting fraction will be rounded up to the nearest whole share of CEIX Common Stock.