Tax Opinions definition

Tax Opinions mean certain Tax opinions and supporting memoranda rendered by Bxxxxxxxx to RemainCo or any of its Affiliates in connection with the Plan of Separation.

Tax Opinions means the Distribution Tax Opinions and the Merger Tax Opinions.

Tax Opinions means the opinions of Tax Advisors deliverable to OFC in connection with the Transactions.

Examples of Tax Opinions in a sentence

• The Parties shall cooperate and use their reasonable best efforts in order to obtain the Tax Opinions.

• The Tax Opinions may state that they relate only to the federal income tax laws of the United States and such counsel need not express any opinion with respect to the applicability thereto, or the effect thereon, of other federal laws, the laws of any state or other jurisdiction or as to any matters of municipal law or the laws of any other local agencies within any state.

• In particular, the Tax Opinions may be conditioned upon certain representations made by the Company as to factual matters through a certificate of an officer of the Company (the “Officer’s Certificate”).

• The Parties shall not take any action or fail to take any action, or permit any of their Affiliates to take any action or fail to take any action, that is or is reasonably likely to be inconsistent with the IRS Ruling, the Tax Representation Letters, or the Tax Opinions.

• The Underwriters will have received the Master Trust Tax Opinions and the Issuer Tax Opinions to the extent required by Section 311 of the Indenture.

More Definitions of Tax Opinions

Tax Opinions means the tax opinions issued by Tax Counsel in connection with the Spin-Off-Related Transactions.

Tax Opinions means the legal opinions delivered to VF by Tax Advisers with respect to certain U.S. federal income Tax consequences of the Restructuring, the Contribution and the Distribution.

Tax Opinions means the opinions of Deloitte Tax LLP deliverable to ParentCo in connection with the Separation Transactions.

Tax Opinions means the Tax opinions and memoranda rendered by any Qualified Tax Advisor to Trident or any of its Affiliates in connection with the Plan of Separation.

Tax Opinions means any opinions of Tax Advisors deliverable to TFMC in connection with the Distribution.

Tax Opinions means (a) the Split-Off Closing Tax Opinion and (b) the Reorganization Tax Opinions.

Tax Opinions means the respective opinions of Wachtell, Lipton, Xxxxx & Xxxx and XxXxxxxxx Will & Xxxxx LLP that each of the exchange of SABMiller Shares for Initial Shares and the exchange of Initial Shares for Restricted Shares will qualify as tax-free reorganizations for U.S. Federal income Tax purposes;