Redemption Tax Opinion definition

Redemption Tax Opinion has the meaning set forth in the Declaration.
Redemption Tax Opinion has the meaning set forth in Annex I to the Declaration.
Redemption Tax Opinion means an opinion of a nationally recognized independent tax counsel (reasonably acceptable to the Issuer Trustees) experienced in such matters that, as a result of a Tax Event, there is more than an insubstantial risk that the Company would be precluded from deducting the interest on the Securities for United States Federal income tax purposes, even after the Trust was liquidated and the Securities were distributed to the holders of the Preferred Securities.

Examples of Redemption Tax Opinion in a sentence

  • Furthermore, if in the case of the occurrence of a Capital Trust Tax Event, the Capital Trust Administrators have received a Capital Trust Redemption Tax Opinion, then the Company shall have the right, within 90 days following the occurrence of such Capital Trust Tax Event, to elect to redeem the Debentures in whole (but not in part) and, in turn, Asset Trust will redeem Asset Trust Preferred Securities in whole (but not in part) for cash upon not less than 30 nor more than 60 days' notice.

  • Unless a Tax Event has occurred and the Company has received a Redemption Tax Opinion, the Debentures will not be redeemable at the option of the Company at any time prior to November 15, 2037.

  • The Sponsor, as the Holder of all of the outstanding Common Securities, has the right at any time to dissolve the Trust (including without limitation upon the occurrence of a Tax Event and receipt of a Redemption Tax Opinion) after satisfaction of liabilities to creditors of the Trust (to the extent not satisfied by the Sponsor), cause the Debentures to be distributed to the Holders of the Trust Securities on a Pro Rata basis in accordance with the aggregate stated liquidation amount thereof.


More Definitions of Redemption Tax Opinion

Redemption Tax Opinion has the meaning specified in Section 9.04(d).
Redemption Tax Opinion means an opinion of independent tax counsel experienced in such matters that, as a result of a Tax Event, there is more than an insubstantial risk that the Company would be precluded from deducting the interest on the Convertible Debentures for United States federal income tax purposes even after the Convertible Debentures were distributed to the holders of Trust Securities in liquidation of such holders' interests in the Trust as described in the Declaration.
Redemption Tax Opinion has the meaning set forth in Section 4(c) of Exhibit A hereto.
Redemption Tax Opinion with respect to a Citigroup Trust, has the meaning set forth in the Declaration of the applicable Citigroup Trust.
Redemption Tax Opinion has the meaning set forth in Section 4 of Annex I ---------------------- hereto.
Redemption Tax Opinion has the meaning set forth in Exhibit A.
Redemption Tax Opinion has the meaning set forth in paragraph 4(c) of Annex I.