Examples of RIHI Initial Common Unit Redemption in a sentence
The WP Common Unit Redemption and the RIHI Initial Common Unit Redemption shall be reflected on Schedule I.
A Net Tax Benefit is “Attributable” to RIHI to the extent that it is derived from any Basis Adjustment, Imputed Interest, or Actual Interest Amount that is attributable to: (i) the RIHI IPO-Related Sale (which, for the avoidance of doubt, is composed of the RIHI Initial Common Unit Redemption and, to the extent applicable, the RIHI Follow-On Common Unit Redemption); or (ii) any RIHI Post-IPO Sale.
Any additional Class A Common Stock sold as a result of the exercise of the Over-Allotment Option shall be sold at the same price as the Class A Common Stock sold in connection with the IPO and the price per Common Unit paid to redeem additional Common Units held by RIHI shall be the same priced paid with respect to the WP Common Unit Redemption and the RIHI Initial Common Unit Redemption.
Holdings and RIHI will each treat Holdings’ purchase of newly issued Common Units from RMCO, followed by (i) the RIHI Initial Common Unit Redemption, and (ii) to the extent that the Over-Allotment Option is exercised, the RIHI Follow-On Common Unit Redemption (collectively, the “RIHI IPO-Related Sale”), as Holdings’ direct purchase of Common Units from RIHI pursuant to Section 707(a)(2)(B) of the Code that will give rise to Basis Adjustments.
For purposes of the RIHI Initial Common Unit Redemption, Holdings and RIHI shall treat the gain recognized by RIHI and the Basis Adjustments obtained by Holdings as occurring as of the date hereof.
Subject only to any principles contained in IRS Revenue Ruling 84-53 that might otherwise require a different result, the aggregate amount of gain recognized by RIHI in connection with the RIHI IPO-Related Sale shall be determined by allocating an equal portion of RIHI’s aggregate adjusted tax basis held in its Common Units to each Common Unit treated as sold by RIHI to Holdings in the RIHI Initial Common Unit Redemption and the RIHI Follow-On Redemption (to the extent that it actually occurs).
Any additional Class A Common Stock sold as a result of the exercise of the Over‑Allotment Option shall be sold at the same price as the Class A Common Stock sold in connection with the IPO and the price per Common Unit paid to redeem additional Common Units held by RIHI shall be the same priced paid with respect to the WP Common Unit Redemption and the RIHI Initial Common Unit Redemption.