Active Trade or Business means the active conduct (determined in accordance with Section 355(b) of the Code) of the business conducted by the WRECO Group members. For these purposes, members shall include only those members that are part of WRECO’s “separate affiliated group” within the meaning of Section 355(b)(3)(B) of the Code.
Active Trade or Business means the active conduct (as defined in Section 355(b)(2) of the Code and the Treasury Regulations thereunder) of the Energy Equipment Business (as defined in the Ruling Request filed with the IRS on February 12, 2018, as supplemented through the Distribution Date, as conducted immediately prior to the Distribution.
Active Trade or Business means the active conduct (determined in accordance with Section 355(b) of the Code) of the trades or businesses described in the Tax Opinion Representations for purposes of satisfying the requirements of Section 355(b) of the Code as it applies to the Transactions with respect to the businesses conducted by members of the SpinCo Group that are the ATB Entities.
Examples of Active Trade or Business in a sentence
TAXon Lump Sum Distribution (SC4972) and/or Active Trade or Business Income (I-335) .
Line 2d - Active Trade or Business Income Deduction: Enter the amount from I-335, line 5.
Active Trade or Business Income Deduction (I-335, line 5)......................
Active Trade or Business Exception Repealed Under previous law, US persons were generally able to transfer assets of a foreign branch used in an active trade or business to a foreign subsidiary on a tax-deferred basis.
The Gregory Rules of Section 355 Business Purpose Active Trade or Business Device (With Additional Thoughts on Control, Continuity of Interest, and OtherSection 355 Miscellany) .................................................................
More Definitions of Active Trade or Business
Active Trade or Business means the active conduct (as defined in Section 355(b)(2) of the Code and the Treasury Regulations thereunder) of the Spinco Business as conducted immediately prior to the Spinco Distribution by the Spinco SAG.
Active Trade or Business means the active conduct of the trade or business (as defined in Section 355(b)(2) of the Code) conducted by Ceva, Inc. immediately prior to the Distribution Date.
Active Trade or Business means the active conduct (as defined in Section 355(b)(2) of the Code and the regulations thereunder) by SpinCo and its “separate affiliated group” (as defined in Section 355(b)(3)(B) of the Code) of the SpinCo Business as conducted immediately prior to the Distribution.
Active Trade or Business means the active conduct (as defined in Section 355(b)(2) of the Code and the regulations thereunder) by GCP and its “separate affiliated group” (as defined in Section 355(b)(3)(B) of the Code) of the Construction Products Business and the Darex Packaging Business, in each case, as conducted immediately prior to the Distribution.
Active Trade or Business means, with respect to each of the ATB Entities, the active conduct (as defined in Section 355(b)(2) of the Code and the Treasury Regulations thereunder) by such entity and its “separate affiliated group” (as defined in Section 355(b)(3)(B) of the Code) of the trades or businesses relied upon to satisfy Section 355(b) of the Code with respect to the Distribution or any other applicable transaction identified in the Tax Opinions/Rulings or Representation Letters.
Active Trade or Business means, (i) with respect to the Distribution, the active conduct (as defined in Section 355(b)(2) of the Code and the Treasury Regulations thereunder, and taking into account the “separate affiliated group” rules of Section 355(b)(3)(B) of the Code) by SpinCo of the Electrical Business as conducted immediately prior to the Distribution, and (ii) with respect to any Internal Distribution in which a SpinCo Entity is the “distributing corporation” (within the meaning of Section 355(a)(1)(A) of the Code) or the “controlled corporation” (within the meaning of Section 355(a)(1)(A) of the Code), the active conduct (as defined in Section 355(b)(2) of the Code and the Treasury Regulations thereunder, and taking into account the “separate affiliated group” rules of Section 355(b)(3)(B) of the Code) by such SpinCo Entity of the portion of the Electrical Business relating to such SpinCo Entity as conducted immediately prior to such Internal Distribution.
Active Trade or Business has the meaning set forth on Exhibit A.