Common use of Favorable Ruling Clause in Contracts

Favorable Ruling. The Foundation shall have received a copy of the Favorable Ruling obtained by BCBSMo, and the Favorable Ruling shall not have been revoked, withdrawn, amended or modified (in whole or in part) and there shall have been no change in applicable law (including, without limitation, the Code, judicial decisions, administrative regulations and published rulings) with regard to matters covered by the Favorable Ruling; provided, however, that in the event that the Internal Revenue Service shall fail to include in the Favorable Ruling any or all Favorable Ruling Matters other than as described in subparagraph (ii) of Section 4.02(f) hereof because such excluded Favorable Ruling Matter is a no ruling area or for any other reason, the Favorable Ruling Matter(s) not so included shall nonetheless be deemed to be included in the Favorable Ruling for purposes of satisfying this condition provided that the Foundation shall have received the opinions provided in Section 4.05(g) hereof on such excluded Favorable Ruling Matter(s) in form and substance reasonably acceptable to the Foundation; and

Favorable Ruling. The Foundation RIT shall have received a copy of the Favorable Ruling obtained by BCBSMo, and the Favorable Ruling shall not have been revoked, withdrawn, amended or modified (in whole or in part) and there shall have been no change in applicable law (including, without limitation, the Code, judicial decisions, administrative regulations and published rulings) with regard to matters covered by the Favorable Ruling; provided, however, that in the event that the Internal Revenue Service shall fail to include in the Favorable Ruling any or all Favorable Ruling Matters other than as described in subparagraph (ii) of Section 4.02(f) hereof because such excluded Favorable Ruling Matter is a no ruling area or for any other reason, the Favorable Ruling Matter(s) not so included shall nonetheless be deemed to be included in the Favorable Ruling for purposes of satisfying this condition provided that the Foundation RIT shall have received the opinions provided in Section 4.05(g4.03(g) hereof on such excluded Favorable Ruling Matter(s) in form and substance reasonably acceptable to the Foundation; andRIT;