Examples of Second Internal Distribution in a sentence
No gain or loss will be recognized by (and no amount will be included in the income of) Distributing upon its receipt of the Controlled 1 stock in the Second Internal Distribution (§ 355(a)(1)).
In respect of each of the Contribution and Distribution, the Second Contribution and Second Internal Distribution, and the First Contribution and First Internal Distribution, this Agreement shall constitute a plan of reorganization for purposes of Section 368 of the Code.
Each of UWWH, IP and Spinco represents and warrants, as of the date hereof and as of the Effective Time, that it knows of no fact (after due inquiry) that would prevent the Tax treatment of the Controlled 1 Contribution, the First Internal Distribution, the Second Internal Distribution, the Third Internal Distribution, the Spinco Contribution, the Distribution or any other Covered Transaction from being consistent with the Tax-Free Status of the Transactions.
TRANSPORTATION COMMITTEE AGENDAThursday, June 13, 2002Staff contact: Kim Kawada, (619) 595-5394 or kka@sandag.org ITEM # RECOMMENDATION CONSENT ITEMS ( 1 to 3) + 1.
The Second Internal Distribution is motivated, in whole or substantial part, by one or more of these corporate business purposes.