Special Tax Event definition

Special Tax Event means that an opinion of a recognized independent tax counsel has been delivered on or after the Issue Date to (i) the Issuer stating that, due to a change in law, ruling or interpretation, the Issuer is, or there is more than an insubstantial risk that the Issuer will be, no longer able to obtain a tax deduction for the purposes of Luxembourg corporation tax for any payment of interest on the Notes and this cannot be avoided by the Issuer taking such reasonable measures as it (acting in good faith) deems appropriate; or(ii) the Guarantor, stating that, due to a change in law, ruling or interpretation, the Guarantor is, or there is more than an insubstantial risk that the Guarantor will be, no longer able to obtain a tax deduction for purposes of Swiss corporation tax for any payment of interest under the Subordinated Guarantee and this cannot be avoided by the Guarantor taking such reasonable measures as it (acting in good faith) deems appropriate.
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Special Tax Event. ’ means that due to a change in law, ruling or interpretation, the Issuer no longer obtains a tax deduction for the purposes of Swiss corporation tax for any payment of interest by the Issuer on the Loan Notes, and this cannot be avoided by the Issuer taking such reasonable measures as it (acting in good faith) deems appropriate. With respect to the occurrence of a Special Tax Event, the Issuer shall deliver to the Fiscal Agent an opinion of a recognised independent tax counsel which confirms such occurrence.
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Special Tax Event means a sale or transfer of all or part of a Member's Percentage Interest that would cause PAH to recognize any of the "built-in gain" with respect to its interests in the Company or the assets of the Company.
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Examples of Special Tax Event in a sentence

  • With respect to the occurrence of a Special Tax Event, the Issuer shall deliver to the Fiscal Agent an opinion of a recognised independent tax counsel which confirms such occurrence.

  • Redemption for Tax Event, Special Tax Event, Regulatory Event, Force Majeure Event or Event of Default:Early Redemption or Monetisation until the Maturity Date Early Redemption Amount : Market ValuePROVISIONS APPLICABLE TO THE UNDERLYING(S) IF ANY24.

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  • Upon the occurrence of any of the events set forth above that give rise to a Par Redemption Event, the Issuer must deliver to the Fiscal Agent a notice bearing the manual signature of two duly authorised officers of the Issuer stating that such Recalculation of Interest Event or Special Tax Event, as the case may be, has occurred as well as a copy of any related opinions.

  • A ―Par Redemption Event‖ means a redemption by the Issuer of the Loan Notes at their principal amount, together with any accrued and unpaid interest, if any, and any outstanding Deferred Interest as of the date on which the Loan Notes are redeemed (but excluding such date) at any time after the issue of the Loan Notes, following a Special Tax Event or a Recalculation of Interest Event that is continuing, or a Regulatory Event.

  • Early Redemption Events Subject to the redemption/purchase limitations described below andto certain other conditions being met, the Issuer may also redeem the outstanding Notes, in whole but not in part, in cash at their principal amount, together with any accrued and unpaid interest and any outstanding Deferred Interest upon the occurrence of a Recalculation Event or a Special Tax Event that is continuing, an Accounting Event, a Ratings Methodology Event or a Regulatory Event.

  • Redemption for Tax Event, Special Tax Event, RegulatoryEarly Redemption or Monetisation until the Maturity Date Early Redemption Amount : Market Value Event, Force Majeure Event or Event of Default: PROVISIONS APPLICABLE TO THE UNDERLYING(S) IF ANY24.

  • The Issuer may also, at its option but subject to the satisfaction of some conditions including the prior written approval of the Relevant Regulator and the Conditions to redemption and purchase, redeem the Notes upon the occurrence of certain events, including a Special Tax Event, a Withholding Tax Event, a Tax Deductibility Event or a Capital Event, all as further described in "Terms and Conditions of the Notes - Redemption and Purchase".

  • The Issuer may, at its option, redeem the Notes, upon the occurrence of certain events and subject to certain conditions (as further described in Condition 6 of the English Law Conditions or Condition 5 of the French Law Conditions ( Redemption, Purchase and Cancellation)), including, but not limited to, a Withholding Tax Event, a Special Tax Event, a Tax Deductibility Event, a Capital Event, and/or a MREL or TLAC Disqualification Event, as the case may be.

  • We may also redeem the Loan Notes in whole but not in part upon the occurrence of a Recalculation of Interest Event or a Special Tax Event (each as defined in the Conditions, and referred to collectively as a “Par Redemption Event”) or upon the occurrence of an Accounting Event, a Regular Tax Event or a Regulatory Event (each as defined in the Conditions, and referred to collectively as a “Make Whole Redemption Event”).


More Definitions of Special Tax Event

Special Tax Event means that due to a change in law, ruling or interpretation we no longer obtain a tax deduction for the purposes of Swiss corporation tax for any payment of interest on the Loan Notes and this cannot be avoided by us taking such reasonable measures as we (acting in good faith) deem appropriate. With respect to the occurrence of a Special Tax Event, we will deliver to the Fiscal Agent an opinion of a recognized independent tax counsel which confirms such occurrence. Make Whole Redemption EventA “Make Whole Redemption Event” means a redemption by us of the Loan Notes at the higher of (1) the Make Whole Amount, and(2) their principal amount together, in each case, with any accrued interest, at any time following (a) an Accounting Event, (b) a Regular Tax Event or (c) a Regulatory Event (each as defined below). Substitution/ Modification followingThe “Make Whole Amount” will equal the sum of the Present Values (as defined in the Conditions) on the date of redemption of (i) the principal amount of the Loan Notes assuming such to be due on the First Optional Redemption Date and (ii) the remaining scheduled payments of interest on the Loan Notes to but excluding the First Optional Redemption Date, using a discount rate equal to 65 basis points above the relevant Bund rate.Where:
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Special Tax Event means an amendment to, or change in, the laws or regulations of any Taxing Jurisdiction affecting taxation, or an amendment to, or change in, an official interpretation or application of such laws or regulations (including, without limitation, pursuant to a final decision or Order of a taxing authority having competent jurisdiction), which amendment or change (a) shall have occurred after November 23, 1999 (or in the case of any jurisdiction that thereafter becomes a Taxing Jurisdiction, as described in Section 22.1, after such jurisdiction becomes a Taxing Jurisdiction) and (b) in the opinion of the Company (which shall be evidenced by an Officer's Certificate and supported by written opinion of counsel having recognized expertise in the field of taxation in the Taxing Jurisdiction, which counsel shall be a firm reasonably satisfactory to the Required Holders and which Officer's Certificate and opinion of counsel shall be delivered to all holders of the Notes prior to any prepayment of Notes under Section 8.7) shall require Additional Payments.
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Special Tax Event means a sale or transfer of all or part of a Member's Percentage Interest that would cause Newco to recognize any of the "built-in gain" with respect to its interests in the Company.
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Special Tax Event means a sale or transfer of all or part of a Member's Percentage Interest that would cause Interstate Management to recognize any of the "built-in gain" with respect to its interests in the Company.
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Special Tax Event has the meaning specified in the definition of “Excluded Taxes.”
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Special Tax Event means that due to a change in law, ruling or interpretation we no longer obtain a tax deduction for the purposes of Swiss corporation tax for any payment of interest on the Loan Notes and this cannot be avoided by us taking such reasonable measures as we (acting in good faith) deem appropriate. With respect to the occurrence of a Special Tax Event, we will deliver to the Fiscal Agent an opinion of a recognized independent tax counsel which confirms such occurrence.
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Related to Special Tax Event

  • Tax Event means the receipt by the Company and the Trust of an opinion of counsel experienced in such matters to the effect that, as a result of any amendment to or change (including any announced prospective change) in the laws or any regulations thereunder of the United States or any political subdivision or taxing authority thereof or therein, or as a result of any official administrative pronouncement (including any private letter ruling, technical advice memorandum, field service advice, regulatory procedure, notice or announcement, including any notice or announcement of intent to adopt such procedures or regulations) (an “Administrative Action”) or judicial decision interpreting or applying such laws or regulations, regardless of whether such Administrative Action or judicial decision is issued to or in connection with a proceeding involving the Company or the Trust and whether or not subject to review or appeal, which amendment, clarification, change, Administrative Action or decision is enacted, promulgated or announced, in each case on or after the date of original issuance of the Debentures, there is more than an insubstantial risk that: (i) the Trust is, or will be within 90 days of the date of such opinion, subject to United States federal income tax with respect to income received or accrued on the Debentures; (ii) interest payable by the Company on the Debentures is not, or within 90 days of the date of such opinion, will not be, deductible by the Company, in whole or in part, for United States federal income tax purposes; or (iii) the Trust is, or will be within 90 days of the date of such opinion, subject to more than a de minimis amount of other taxes, duties or other governmental charges.

  • Special Tax means the special tax to be levied in each Fiscal Year on each Assessor’s Parcel of Taxable Property to fund the Special Tax Requirement.

  • Special Taxes means any and all present or future taxes, levies, imposts, deductions, charges or withholdings, or any liabilities with respect thereto, including those arising after the date hereof as result of the adoption of or any change in law, treaty, rule, regulation, guideline or determination of a Governmental Authority or any change in the interpretation or application thereof by a Governmental Authority but excluding, in the case of Lender, such taxes (including income taxes, franchise taxes and branch profit taxes) as are imposed on or measured by Lender’s net income by the United States of America or any Governmental Authority of the jurisdiction under the laws under which Lender is organized or maintains a lending office.

  • Special Tax Requirement means that amount required in any Fiscal Year to: (i) pay debt service on all Outstanding Bonds; (ii) pay periodic costs on the Bonds, including but not limited to, credit enhancement and rebate payments on the Bonds; (iii) pay Administrative Expenses; (iv) pay any amounts required to establish or replenish any reserve funds for all Outstanding Bonds; (v) pay directly for the acquisition or construction of facilities authorized to be financed by IA No. 2 to the extent that inclusion of such amount does not increase the Special Tax levy on Undeveloped Property; and (vi) pay for reasonably anticipated Special Tax delinquencies based on the historical delinquency rate for IA No. 2 as determined by the CFD Administrator; less (vii) a credit for funds available to reduce the annual Special Tax levy, as determined by the CFD Administrator pursuant to the Indenture.

  • Tax Event Repayment Date means the date set out in a notice from the Issuer to the Bondholders pursuant to Clause 10.4 (Early redemption option due to a tax event).

  • Maximum Special Tax means the maximum Special Tax, determined in accordance with Section C below, that can be levied in any Fiscal Year on any Assessor’s Parcel.

  • Tax Event Redemption Date means the date upon which a Tax Event Redemption is to occur.

  • Agreement combined tax rate means the sum of the tax rates:

  • Annual Special Tax means the Special Tax actually levied in any Fiscal Year on any Assessor’s Parcel.

  • Change in Tax Law means the enactment, promulgation, execution or ratification of, or any change in or amendment to, any law (or in the application or official interpretation of any law) that occurs on or after the date on which the relevant Transaction is entered into.

  • Special Event means any of a Tax Event, an Investment Company Event or a Capital Treatment Event.

  • ii) Event means any event described in Section 11(a)(ii) hereof.

  • Backup Annual Special Tax means the Special Tax of that name described in Section E.

  • maximum council tax reduction amount means the amount determined in accordance with paragraph 29;

  • Special Events means sports complex events, City of Pittsburgh events, weather, and other events that have been or are identified as such by the RTMC.