US Ruling definition

US Ruling means the private letter ruling issued by the IRS to Remainco in connection with the Restructuring and the Distribution, together with any supplements issued by, and submissions to, the IRS with respect to such ruling;
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Examples of US Ruling in a sentence

  • Rick Weiss, U.S. Ruling Aids Opponent of Patents for Life Forms, WASH.

  • Robert Iafolla & Daniel Wiessner, Browning-Ferris Fights U.S. Ruling on ‘Joint-Employment’ in Court, REUTERS (June 7, 2016, 6:22 PM), http://www.reuters.com/article/us-browningferris-nlrb-idUSKCN0YT2PQ [https://perma.cc/PQ3P-MMDR] (reporting the director of labor policy at the Chamber of Commerce’s warning that the decision will eliminate jobs).

  • Rick Weiss, US Ruling Aids Opponent of Patents for Life Forms, The Washington Post, June 17, 1999, at A2.Rather than waiting for case-by-case controversies to arise, the PTO should initiate consideration of how to design principles and procedures that would better protect moral values in the context of patenting living organisms.

  • At the sole discretion of the Manager, for trees less than fifteen (15) feet in height, ladders may be used which are free-standing and do not touch the tree trunk.

  • If Mr. Bratt is correct that his sentence at the time he filed his 2018 motion was illegal, that means the court was correct to strike it and impose a new sentence,his motion for modification was timely, and the court may consider it.

  • Impetus from a U.S. Ruling The key U.S. regulatory ruling by the Federal Energy Regulatory Commission (FERC) driving the AIT’s energy negotiations essentially makes it impossible for Canadian utilities to use American transmission lines when selling elect ricity south of the border unless reciprocal access is provided to suppliers of U.S. electricity who might wish to sell to Canada.

  • The Impact of the U.S. Ruling Class on the Rest of the World The devastation caused by the U.S. ruling class is incalculable.

  • Dispute Within the U.S. Ruling Class Jeffrey’s comments were somewhat surprising, as his arrival in mid-2018 was widely heralded as a “toughening up” of the Trump regime’s stance on Assad.

  • Hannah Monicken, U.S.: Ruling on 232 Tariffs Would Undermine ‘Viability’ of WTO, WORLD TRADE ONLINE (Oct.

  • U.S.: Ruling on 232 tariffs would undermine 'viability' of WTO,” Inside U.S. Trade, October 29, 2018.

Related to US Ruling

  • IRS Ruling shall have the meaning set forth in the Recitals.

  • Tax Ruling as used in this Agreement, shall mean a written ruling of a taxing authority relating to Taxes. "Closing Agreement", as used in this Agreement, shall mean a written and legally binding agreement with a taxing authority relating to Taxes.

  • 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.

  • advance ruling means a decision provided by the Authority or the Appellate Authority to an applicant on matters or on questions specified in sub-section (2) of section 97 or sub-section (1) of section 100, in relation to the supply of goods or services or both being undertaken or proposed to be undertaken by the applicant;

  • Private Letter Ruling shall have the meaning set forth in the Recitals.

  • Supplemental Ruling means (i) any ruling (other than the Ruling) issued by the IRS in connection with a Distribution, and (ii) any similar ruling issued by any other Taxing Authority addressing the application of a provision of the laws of another jurisdiction to a Distribution.

  • Ruling Request means any letter filed by Parent with the IRS requesting a ruling regarding certain tax consequences of the Transactions (including all attachments, exhibits, and other materials submitted with such ruling request letter) and any amendment or supplement to such ruling request letter.

  • IRS means the United States Internal Revenue Service.

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

  • Ruling Documents means the Ruling and the Ruling Request.

  • Tax Opinion means, with respect to any action, an Opinion of Counsel to the effect that, for federal income tax purposes, (i) following such action the Trust will not be deemed to be an association (or publicly traded partnership) taxable as a corporation, (ii) following such action the Trust will be disregarded as a separate entity from the Depositor, and (iii) such action will not affect the tax characterization as debt of Notes of any outstanding Class issued by the Trust for which an Opinion of Counsel has been provided that such Notes are debt.

  • Resource Adequacy Rulings means CPUC Decisions 00-00-000, 00-00-000, 00-00-000, 06- 06-024, 00-00-000 and any subsequent CPUC ruling or decision, or any other resource adequacy laws, rules or regulations enacted, adopted or promulgated by any applicable Governmental Authority, as such CPUC decisions, rulings, laws, rules or regulations may be amended or modified from time to time during the Term.

  • foreign firm means a business entity owned or controlled by one or more foreign nationals or a business entity in which more than 50 percent of the stock is owned or controlled by one or more foreign nationals.

  • External dose means that portion of the dose equivalent received from any source of radiation outside the body.

  • Debt-For-Tax Opinion means an Opinion of Counsel, of nationally recognized tax counsel, delivered to the Depositor and the Indenture Trustee stating that the Notes will be debt for United States federal income tax purposes.

  • council tax benefit means council tax benefit under Part 7 of the SSCBA; “couple” has the meaning given by paragraph 4;

  • Tax Counsel shall have the meaning set forth in Section 6.2 hereof.

  • Issuer Tax Opinion means with respect to any action, an Opinion of Counsel to the effect that, for federal income tax purposes and subject to customary assumptions and qualifications for opinions of this type, (a) such action will not adversely affect the tax characterization as debt of any Notes that were characterized as debt at the time of their issuance, and (b) following such action neither the Issuer nor the Titling Trust will be treated as an association (or publicly traded partnership) taxable as a corporation.

  • Internal dose means that portion of the dose equivalent received from radioactive material taken into the body.

  • ITA means the Income Tax Act (Canada), as amended;

  • Foreign Financial Regulatory Authority shall have the meaning given by Section 2(a)(50) of the 0000 Xxx.

  • Tax Regulatory Agreement means the Tax Regulatory Agreement dated as of the date hereof by and among the Company, the Issuer and the Trustee.

  • Internal Distribution has the meaning set forth in the recitals.

  • Income Tax Return means any return, declaration, report, claim for refund, or information return or statement relating to Income Taxes, including any schedule or attachment thereto, and including any amendment thereof.

  • Unqualified Tax Opinion means an unqualified reasoned “will” opinion of Qualified Tax Counsel, which opinion is reasonably acceptable to each of the Parties and upon which each of the Parties may rely to confirm that a transaction (or transactions) will not result in Distribution Taxes. For purposes of this definition, an opinion is reasoned if it describes the reasons for the conclusions, including the facts and analysis supporting the conclusions.

  • Independent Tax Counsel means a lawyer, a certified public accountant with a nationally recognized accounting firm, or a compensation consultant with a nationally recognized actuarial and benefits consulting firm with expertise in the area of executive compensation tax law, who shall be selected by the Employer and shall be reasonably acceptable to the Executive, and whose fees and disbursements shall be paid by the Employer.