Section 351 Transaction definition

Section 351 Transaction has the meaning assigned to that term in the LLC Agreement.
Section 351 Transaction means, if the Acquisition is structured as a transaction qualifying for the deferral of federal income tax under Section 351 of the Code, that transaction.
Section 351 Transaction means a tax-deferred exchange within the meaning of Section 351 of the U.S. Code.

Examples of Section 351 Transaction in a sentence

  • The Corporation shall issue its stock in the Section 351 Transaction in accordance with the Incorporation Plan, which shall specify the classes of stock for which the Units (or shares of stock of a Member that is a corporation, as applicable) shall be exchanged and which shall attach as an exhibit the form of organizational document which shall set forth the rights and privileges of such classes of stock.

  • It is the intent of the parties hereto that the transactions described herein constitute and qualify as a tax-free transaction pursuant to section 351 of the Code (a "Section 351 Transaction").

  • CONFERENCE ROOM 2 CODE CLASSWednesday, January 22nd, 8:00 a.m. - 12:00 p.m. Byron Krull is an instructor in the Industrial Commercial Wiring program at Northwest Iowa Community College in Sheldon Iowa.

  • The segment has four wind farms in operation,Smøla, Hitra and Kjøllefjord in Norway and Alltwalis in the UK.

  • This claim was inconsistent with the failure to report any boot gain in the Section 351 Transaction.


More Definitions of Section 351 Transaction

Section 351 Transaction has the meaning assigned to that term in the Limited Liability Company Agreement.
Section 351 Transaction has the meaning set forth in the recitals.
Section 351 Transaction has the meaning set forth in Article XIII.
Section 351 Transaction means a tax-free contribution of Class A LLC Units and/or Class B LLC Units in Orbitz LLC to the Corporation in exchange for Securities of the Corporation pursuant to Section 351 of the Code, and which complies with the provisions of Section 9 of the Stockholders Agreement.
Section 351 Transaction has the meaning set forth in Section 14.1.
Section 351 Transaction means a transaction as defined in Section 351 of the Code.
Section 351 Transaction means a transaction intended to qualify for nonrecognition of gain or loss under Section 351(a) of the Code, except to the extent that gain is required to be recognized pursuant to Section 351(b) of the Code.