Examples of Substantial Authority in a sentence
Such treatment reported on any Tax Return for which Cyclerion is the Responsible Party shall be consistent with that on any Tax Return filed or to be filed by Ironwood or any member of the Ironwood Group or caused or to be caused to be filed by Ironwood, unless the Parties jointly determine that there is not Substantial Authority for such Tax treatment.
Such treatment reported on any Tax Return for which 2seventy is the Responsible Party shall be consistent with that on any Tax Return filed or to be filed by bluebird or any member of the bluebird Group or caused to be filed by bluebird, unless the Parties jointly determine that there is not Substantial Authority for such Tax treatment.
The Lenders shall use commercially reasonable efforts to deliver to the Company and the applicable Borrower a Substantial Authority Recast Opinion with respect to the Cash Loan made to such Borrower at the time such Cash Loan is made (which opinion, for the avoidance of doubt, shall be obtained at the expense of the Lenders).
For this purpose, the Tax treatment shall be determined by ConocoPhillips and shall be agreed to by Xxxxxxxx 66 unless either (i) no Substantial Authority exists for the technical merits of the position, or (ii) such Tax treatment is inconsistent with the Tax treatment contemplated in the Ruling Requests, the Tax Opinions/Rulings and/or the ConocoPhillips Group Transaction Returns.
Xxxxxxxx 66 shall use reasonable best efforts to respond in writing to ConocoPhillips with any comments no later than the date on which ConocoPhillips files such Tax Return with the applicable Tax Authority, provided, however that Xxxxxxxx 66’s comments shall be limited to the reporting of any material Tax Item on such Tax Return with respect to which Xxxxxxxx 66 reasonably believes that no Substantial Authority exists for the technical merits of the position.