Distribution Upon Adverse Judgment. Notwithstanding anything to the contrary in this Section IV, your vested Units shall be become immediately distributable to you if (A) the Internal Revenue Service (the “IRS”) successfully challenges, in a court of competent jurisdiction, any deferral election made by you in accordance with subsection (a) with respect to such Units, and (B) as a result of which, you have a taxable event with respect to such Units. Such distribution shall be made no later than thirty (30) days following the final judgment of a court of competent jurisdiction upholding the position of the IRS with respect to the taxation of such Units.
Appears in 4 contracts
Samples: Performance Restricted Stock Unit Agreement (Health Care Property Investors Inc), Performance Restricted Stock Unit Agreement (Health Care Property Investors Inc), Performance Restricted Stock Unit Agreement (Health Care Property Investors Inc)
