Trust Redemption Tax Opinion definition

Trust Redemption Tax Opinion means an opinion of nationally recognized independent tax counsel experienced in such matters that there has been a Trust Tax Event, and following such Trust Tax Event there is more than an insubstantial risk that interest payable by one or more of the Investment Affiliates with respect to the Debentures is not, or will not be, deductible by such Investment Affiliate for United States federal income tax purposes even if the Partnership Preferred Securities were distributed to the Holders of the Trust Securities in liquidation of such Holders' interests in the Trust.
Sample 1Sample 2Sample 3
Trust Redemption Tax Opinion means an opinion of nationally recognized independent tax counsel experienced in such matters that there has been a Tax Event, and following such Tax Event there is more than an insubstantial risk that interest payable by One Sierra Pacific with respect to the Debentures is not, and will not be deductible by Sierra Pacific for United States federal income tax purposes even if the Debentures were distributed to the Holders of the Trust Securities in liquidation of such Holders' interests in the Trust.
Sample 1Sample 2
Trust Redemption Tax Opinion means an opinion of nationally recognized independent tax counsel (which may be counsel for the Company) experienced in such matters that there has been a Trust Tax Event, and following such Trust Tax Event there is more than an insubstantial risk that interest payable by one or more of the Investment Affiliates with respect to the Initial Debentures issued by such Investment Affiliate is not, or will not be, deductible by such Investment Affiliate for United States federal income tax purposes even if the Partnership Preferred Securities were distributed to the Holders of the Trust Securities in liquidation of such Holders' interests in the Trust.
Sample 1

Examples of Trust Redemption Tax Opinion in a sentence

  • Furthermore, if in the case of the occurrence of a Capital Trust Tax Event, the Capital Trust Administrators have received a Capital Trust Redemption Tax Opinion, then the Company shall have the right, within 90 days following the occurrence of such Capital Trust Tax Event, to elect to redeem the Debentures in whole (but not in part) and, in turn, Asset Trust will redeem Asset Trust Preferred Securities in whole (but not in part) for cash upon not less than 30 nor more than 60 days' notice.


More Definitions of Trust Redemption Tax Opinion

Trust Redemption Tax Opinion means an opinion of nationally recognized independent tax counsel in the United States or the United Kingdom, as the case may be, experienced in such matters to the effect that there has been a Trust Tax Event, and that, as a result of the occurrence of such Trust Tax Event, there is more than an insubstantial risk that interest payable by an Investment Affiliate with respect to the Affiliate Investment Instruments issued by such Investment Affiliate is not, or will not be, fully deductible by such Investment Affiliate for United States federal income tax or United Kingdom corporation tax or income tax purposes.
Sample 1
Trust Redemption Tax Opinion means an opinion of nationally recognized independent tax counsel experienced in such matters that there has been a Trust Tax Event, and following such Trust Tax Event there is more than an insubstantial risk that interest payable by one or more of the Investment Affiliates with respect to the Debentures is not, or will not be, deductible by such Investment Affiliate for United States federal income tax purposes even if the Partnership Preferred Securities were distributed to the Holders of the Trust Securities in liquidation of such Holders' interests in the Trust. "Trust Securities" means the Trust Common Securities and the Trust Preferred Securities. "Trust Special Event" means a Trust Tax Event or a Trust Investment Company Event. "Trust Tax Event" means that there has been a Tax Action which relates to any of the items described in (i) through (iii) below, and that there is more than an insubstantial risk that (i) the Trust is, or will be subject to United States federal income tax with respect to income accrued or received on the Partnership Preferred Securities, (ii) the Trust is, or will be, subject to more than a DE MINIMIS amount of other taxes, duties or other governmental charges or (iii) interest payable by one or more of the Investment Affiliates with respect to the Debentures is not, or will not be, deductible by such Investment Affiliate for United States federal income tax purposes. "Trustee" or "Trustees" means each Person who has signed this Declaration as a trustee, so long as such Person shall continue in office in accordance with the terms hereof, and all other Persons who may from time to time be duly appointed, qualified and serving as Trustees in accordance with the provisions hereof, and references herein to a Trustee or the Trustees shall refer to such Person or Persons solely in their capacity as trustees hereunder. 11
Sample 1
Trust Redemption Tax Opinion means an opinion of nationally recognized independent tax counsel experienced in such matters that there has been a Trust Tax Event, and following such Trust Tax Event there is more than an insubstantial risk that (i) interest payable by one or more of the Investment Affiliates with respect to the Affiliate Investment Instruments is not, or will not be, deductible by such Investment Affiliate for United States federal or United Kingdom corporate income tax purposes or (ii) Additional Amounts (as defined in the Indentures, the Partnership Guarantee and the Trust Guarantees) are, or would be, payable in respect of Affiliate Investment Instruments, any Investment Guarantee, the Partnership Guarantee or any Trust Guarantee, even if the Preferred Partnership Securities were distributed to the Holders of the Preferred Trust Securities in liquidation of such Holders' interests in the Trust.
Sample 1
Trust Redemption Tax Opinion means an opinion of nationally recognized independent tax counsel in the United States or the United Kingdom, as the case may be, experienced in such matters to the effect that there has been a Trust Tax Event, and that, as a result of the occurrence of such Trust Tax Event, there is more than an insubstantial risk that interest payable by an Investment Affiliate with respect to the Affiliate Investment Instruments issued by such Investment Affiliate is not, or will not be, fully deductible by such Investment Affiliate for United States federal income tax or United Kingdom corporation tax or income tax purposes even if the Preferred Partnership Securities were distributed to the Holders of the Preferred Trust Securities in liquidation of such Holders'interests in the Trust.
Sample 1

Related to Trust Redemption Tax Opinion

  • Tax Event Redemption Price means an amount equal to the unpaid principal amount of this Note to be redeemed, which shall be determined by multiplying (1) the Outstanding Principal Amount of this Note by (2) the quotient derived by dividing (A) the outstanding principal amount to be redeemed by Principal Life of the Funding Agreement by (B) the outstanding principal amount of the Funding Agreement.

  • Tax Redemption The meaning specified in Section 9.3(a) hereof.

  • Tax Event Redemption means, if a Tax Event shall occur and be continuing, the redemption of the Notes, at the option of the Company, in whole but not in part, on not less than 30 days nor more than 60 days' written notice.

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

  • Tax Redemption Date means, when used with respect to any Note to be redeemed pursuant to a Tax Redemption, the date fixed for such Tax Redemption pursuant to this Indenture.

  • Mandatory Redemption Event has the meaning given to it in Condition 8.7.

  • Early Redemption Event means that R (k) is equal to or greater than the Early Redemption Level (k) on the respective Observation Date (k).

  • Special Event Redemption Price has the meaning specified in Section 11.2.

  • Series A Redemption Date has the meaning set forth in Section 16.6.

  • Series A Redemption Price has the meaning set forth in Section 16.6(a).

  • Special Mandatory Redemption Event has the meaning specified in Section 3.02(a) hereto.

  • Special Redemption Price has the meaning set forth in paragraph 4(a) of Annex I.

  • Mandatory Redemption Price means $25,000 per share of AMPS plus an amount equal to accumulated but unpaid dividends (whether or not earned or declared) to the date fixed for redemption and excluding Additional Dividends.

  • Series A Redemption Notice has the meaning set forth in Section 16.6(b).

  • Redemption Event has the meaning set forth in Section 3.4.

  • Mandatory Redemption Amount means an amount per ETP Security calculated by the Determination Agent equal to the greater of:

  • Mandatory Redemption means a redemption of ETP Securities in accordance with Condition 8.7.

  • Special Mandatory Redemption Price has the meaning set forth in Section 4.03(a).

  • Special Redemption has the meaning set forth in Section 15.1.A hereof.

  • Note Redemption Price means, for the Redemption Date, an amount equal to the sum of:

  • Mandatory Redemption Settlement Date means, in respect of a Mandatory Redemption Event, the day that falls three Currency Business Days after the day on which the Issuer has received payment in full from the Margin Loan Provider of the amounts payable in respect of the termination of the LS Margin Account Agreement.

  • Special Redemption Date has the meaning set forth in Section 10.2.

  • Early Redemption Amount means in respect of each Note in circumstances where such Notes are redeemed early pursuant to Conditions 7(b) or (c), the outstanding principal amount of each Note, unless otherwise specified in the Final Terms or Series Offering Document, as applicable;

  • Indenture Redemption Price has the meaning specified in Section 4.2(c).

  • Optional Redemption Pricing Date means a Valuation Date on which a Redemption Order is determined to be valid and accepted by or on behalf of the Issuer in accordance with the terms of the LS Operating Procedures Agreement.

  • Redemption Rescission Event means the occurrence of (a) any general suspension of trading in, or limitation on prices for, securities on the principal national securities exchange on which shares of Common Stock or Marketable Securities are registered and listed for trading (or, if shares of Common Stock or Marketable Securities are not registered and listed for trading on any such exchange, in the over-the-counter market) for more than six-and-one-half (6-1/2) consecutive trading hours, (b) any decline in either the Dow Xxxxx Industrial Average or the S&P 500 Index (or any successor index published by Dow Xxxxx & Company, Inc. or S&P) by either (i) an amount in excess of 10%, measured from the close of business on any Trading Day to the close of business on the next succeeding Trading Day during the period commencing on the Trading Day preceding the day notice of any redemption of Securities is given (or, if such notice is given after the close of business on a Trading Day, commencing on such Trading Day) and ending at the time and date fixed for redemption in such notice or (ii) an amount in excess of 15% (or if the time and date fixed for redemption is more than 15 days following the date on which such notice of redemption is given, 20%), measured from the close of business on the Trading Day preceding the day notice of such redemption is given (or, if such notice is given after the close of business on a Trading Day, from such Trading Day) to the close of business on any Trading Day at or prior to the time and date fixed for redemption, (c) a declaration of a banking moratorium or any suspension of payments in respect of banks by Federal or state authorities in the United States or (d) the occurrence of an act of terrorism or commencement of a war or armed hostilities or other national or international calamity directly or indirectly involving the United States which in the reasonable judgment of the Company could have a material adverse effect on the market for the Common Stock or Marketable Securities.