Tax Opinions/Rulings means (i) any Ruling and (ii) any opinion of a Tax Advisor relating to the Transactions, including those issued on the Distribution Date or to allow a party to take actions otherwise prohibited under Section 4.03(a) of this Agreement.
Tax Opinions/Rulings means (i) the opinions of Wachtell, Lipton, Xxxxx & Xxxx and of PwC deliverable to Parent pertaining to or in connection with, and regarding the Federal Income Tax treatment of, the Internal Distribution, the Contribution and/or the Distribution and (ii) any Rulings.
Tax Opinions/Rulings means each opinion of a Tax Advisor or ruling by the IRS or another Tax Authority delivered or issued to Parent or any of its subsidiaries in connection with, and regarding the tax treatment of the Contribution and Distribution, any Internal Distribution, Internal Contribution or any Non-U.S. Separation Transaction.
More Definitions of Tax Opinions/Rulings
Tax Opinions/Rulings means the opinions of Tax Counsel and/or the rulings by the IRS or other Tax Authorities delivered to Parent in connection with the Spin-Off, or otherwise with respect to the Separation Transactions.
Tax Opinions/Rulings means the opinion or opinions of Tax Advisors deliverable to Distributing in connection with the Contribution and the Distribution and/or the Ruling or Rulings.
Tax Opinions/Rulings means any opinions of Tax Advisors deliverable to Parent in connection with the Transactions regarding the Federal Income Tax treatment of all or any part of the Transactions and any Rulings.
Tax Opinions/Rulings shall have the meaning given to such term in the Tax Matters Agreement.
Tax Opinions/Rulings means the opinions of Tax Advisors and/or the rulings by the IRS or other Tax Authorities deliverable to Pfizer in connection with the Contribution and the Distribution or otherwise with respect to the Separation Transactions.
Tax Opinions/Rulings means (x) the formal written opinions or similar memoranda of a Tax Advisor regarding the Tax-Free Status or any intended tax treatment of a Separation Transaction that is described on Schedule 2 attached hereto and/or (y) the rulings by the IRS or other Tax Authority received in respect of a Ruling Request delivered to Houston (and made available to Seattle or, if prior to the Effective Time, Miami), in each case, in connection with the Contribution, the Distribution or the Merger or otherwise with respect to the Separation Transactions, including, for the avoidance of doubt, the Houston Tax Opinion.
Tax Opinions/Rulings means (i) any Ruling and (ii) any opinion of a Tax Advisor relating to the Spin-Off, including the Cravath Tax Opinion and any opinion issued to allow a party to take actions otherwise prohibited under Section 4.04(a) of this Agreement.