Section 336(e) Election definition

Section 336(e) Election has the meaning set forth in Section 7.06.

Section 336(e) Election has the meaning set forth in Section 3.4.

Section 336(e) Election shall have the meaning set forth in Section 4(d).

Examples of Section 336(e) Election in a sentence

• Accordingly, the Parties agree that this Agreement constitutes a written, binding agreement to make a Protective Section 336(e) Election as contemplated by Section 1.336-2(h)(1)(i) of the Regulations.

• To the extent the Protective Section 336(e) Election becomes effective, each Party agrees not to take any position (and to cause each of its Affiliates not to take any position) that is inconsistent with the Protective Section 336(e) Election, including the Section 336(e) Allocation Statement, on any Tax Return, in connection with any Tax Contest or for any other Tax purposes (in each case, excluding any position taken for financial accounting purposes), except as may be required by a Final Determination.

• To the extent the Section 336(e) Election becomes effective, each Party agrees not to take any position (and to cause each of its Affiliates not to take any position) that is inconsistent with the Section 336(e) Election, including the Section 336(e) Allocation Statement, on any Tax Return, in connection with any Tax Contest or for any other Tax purposes (in each case, excluding any position taken for financial accounting purposes), except as may be required by a Final Determination.

• To the extent, pursuant to a Final Determination, the Distribution constitutes a “qualified stock disposition,” as defined in Treasury Regulation Section 1.336-1(b)(6), the Parties shall not and shall not permit any of their respective Subsidiaries to, take any position for Tax purposes inconsistent with the relevant Protective Section 336(e) Election, except as may be required pursuant to a Final Determination.

• It is intended that a Section 336(e) Election will have no effect unless the Distribution is a “qualified stock disposition,” as defined in Treasury Regulations Section 1.336(e)-1(b)(6), by reason of the application of Treasury Regulations Section 1.336-1(b)(5)(i)(B) or Treasury Regulations Section 1.336-1(b)(5)(ii), or under any comparable provisions of state, local or non-U.S. law in any other jurisdiction.

More Definitions of Section 336(e) Election

Section 336(e) Election has the meaning set forth in Section 2.09.

Section 336(e) Election shall have the meaning set forth in Section 7.06 of this Agreement.

Section 336(e) Election has the meaning set forth in the Tax Matters Agreement.

Section 336(e) Election has the meaning set forth in Section 7.06. “Section 7.02(e) Acquisition Transaction” means any transaction or series of transactions that is not a Proposed Acquisition Transaction but would be a Proposed Acquisition Transaction if the percentage reflected in the definition of Proposed Acquisition Transaction were 25% instead of 40%.

Section 336(e) Election means an election made pursuant to Section 336(e) of the Code.

Section 336(e) Election shall have the meaning assigned to it in Section 15.01.

Section 336(e) Election has the meaning set forth in Section 5.8(a).