Examples of RSA Fee in a sentence
In the case of the Second Lien Notes Equity RSA Fee that is payable in New Common Stock, to the extent such Fee is subject to withholding, it is possible that the withholding tax would be withheld from or set off against any amount owed to or received from a Non-U.S. Holder, including, but not limited to, payments on the New Common Stock, sale proceeds received by the Non-U.S. Holder, or other of such Holder’s funds or assets.
Based on such applicable Treasury Regulations, the exchange of Allowed First Lien Notes Claim for Exit Secured Notes and First Lien Notes Cash RSA Fee pursuant to the Plan is expected to be treated as a “significant modification” of the First Lien notes and accordingly as a taxable “exchange” under section 1001 of the Tax Code of the First Lien Notes for Cash and different debt of Reorganized Pyxus for U.S. federal income tax purposes.
Work may continue on other parts of the building site while historical or unique archaeological resources mitigation takes place (CEQA Guidelines rev.
Except with respect to accrued market discount and subject to the discussion below under “First Lien Notes Cash RSA Fee and Second Lien Notes Equity RSA Fee,” any gain or loss a U.S. Holder recognized in the exchange generally would be capital gain or loss and would be long-term capital gain or loss if the First Lien Notes had been held for more than one year.
As discussed above under “U.S. Federal Income Tax Consequences of the Consummation of the Plan— First Lien Notes Cash RSA Fee and Second Lien Notes Equity RSA Fee,” the U.S. federal income tax treatment of the Fees is unclear.
As such, subject to the discussion below under “Accrued Interest” and “First Lien Notes Cash RSA Fee and Second Lien Notes Equity RSA Fee”, a U.S. Holder of an Allowed Second Lien Notes Claim is not expected to recognize any gain or loss on the exchange.
Accordingly, such a Consenting Creditor will not be entitled to any RSA Fee.
The U.S. federal income tax treatment of the Cash RSA Fee and Equity RSA Fee (the “Fees”) is unclear.
Not eligible for any RSA Fee 5 If you are in any doubt as to how to complete this form, please immediately contact the Information Agent.6 The Transfer Notice is only required to be executed by a Transferor who is a Consenting Creditor.
If a debt instrument constituting a surrendered Allowed Second Lien Notes Claim is treated as a “security” for U.S. federal income tax purposes, the receipt of New Common Stock (including any Second Lien Notes Equity RSA Fee that is payable in New Common Stock) by the U.S. Holder of the Allowed Second Lien Notes Claim in exchange for such Allowed Second Lien Notes Claim will be treated as a “recapitalization,” and therefore a reorganization for U.S. federal income tax purposes.