Supplemental Ruling definition

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.

Supplemental Ruling means any private letter ruling obtained by Distributing or Spinco from the IRS which supplements or otherwise modifies the Ruling.

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 Tax Authority addressing the application of a provision of the laws of another jurisdiction to a Distribution.

Examples of Supplemental Ruling in a sentence

• Each of the Parties agrees that at the reasonable request of the other Party (the “Requesting Party”), such Party shall cooperate and use reasonable efforts to (and shall cause its Subsidiaries to cooperate and use reasonable efforts to) assist the Requesting Party in obtaining, as expeditiously as reasonably practicable, a Supplemental Ruling from the IRS and/or a Supplemental Tax Opinion from Tax Counsel.

• WhiteWave agrees that, at the request of Xxxx Foods, WhiteWave shall cooperate fully with Xxxx Foods to take any action necessary or reasonably helpful to effectuate the Distribution or the Equity for Debt Exchanges, including seeking to obtain, as expeditiously as possible, a Tax Opinion, Supplemental Tax Opinion, Ruling, and/or Supplemental Ruling.

• The Requesting Party shall reimburse the other parties for all reasonable out-of-pocket costs and expenses incurred by such parties or their Subsidiaries or Affiliates in connection with obtaining or requesting such Supplemental Ruling within five business days after receiving an invoice from such party therefor.

• The Requesting Party shall reimburse the other parties for all reasonable out-of-pocket costs and expenses incurred by such parties or their Affiliates in connection with obtaining or requesting such Supplemental Ruling within five business days after receiving an invoice from such party therefor.

• VMware agrees that, at the request of Dell Technologies, VMware shall cooperate fully with Dell Technologies to take any action necessary or reasonably helpful to effectuate a Distribution, including seeking to obtain, as expeditiously as possible, a Tax Opinion, Supplemental Tax Opinion, Ruling, and/or Supplemental Ruling.

More Definitions of Supplemental Ruling

Supplemental Ruling means any IRS private letter ruling issued in connection with the Restructuring and/or Distribution other than the IRS Ruling Request.

Supplemental Ruling means (1) any ruling issued by the Service in connection with the Spinoff other than the Initial Private Letter Ruling or (2) any similar ruling issued by any other Tax Authority addressing the application of a provision of the laws of another jurisdiction to the Spinoff.

Supplemental Ruling means a private letter ruling, without substantive qualifications, of the IRS, to the effect that a transaction will not affect the Tax-Free Status of the Transactions.

Supplemental Ruling means a private letter ruling from the IRS on the matters listed in Exhibit G to this Agreement.

Supplemental Ruling means any ruling (other than the IRS Ruling) issued by any Taxing Authority in connection with the Spin-Off.

Supplemental Ruling means any ruling issued after the issuance of the Initial IRS Ruling (a) by the IRS in connection with the Distribution or any transactions undertaken in connection with the Distribution or (b) by any other Tax Authority, addressing the application of a provision of the laws of another jurisdiction to any transaction undertaken in connection with the Distribution.

Supplemental Ruling means any U.S. federal income Tax ruling which may be issued by the IRS to the effect that a transaction will not affect the Tax-Free Status of the Distributions or the Mergers.