Federal Tax Treatment. Notwithstanding anything to the contrary contained in this Agreement or any document delivered herewith, all persons may disclose to any and all persons, without limitation of any kind, the federal income tax treatment of the Notes, any fact relevant to understanding the federal tax treatment of the Notes, and all materials of any kind (including opinions or other tax analyses) relating to such federal tax treatment.
Federal Tax Treatment. Subject to the qualifications, limitations and assumptions set forth in the Registration Statement, the General Disclosure Package and the Prospectus, the Company expects to be treated as a foreign corporation for U.S. federal income tax purposes, taking into account Section 7874 of the Code.
Federal Tax Treatment. Qualified ABLE Program. CalABLE is designed to be, and is intended to satisfy the requirements for treatment as, a qualified ABLE program under Section 529A. The IRS provides important information on the taxation of qualified ABLE programs in IRS Publication 907 available at xxxxx://xxx.xxx.xxx/pub/irs- pdf/p907.pdf. Contributions. Contributions to an Account generally will not result in taxable income to the Account Owner. Contributions are made on an after-tax basis. A contributor may not deduct the contribution from income for the purposes of determining federal income tax liability.
Federal Tax Treatment. The Parties intend that the transactions effected pursuant to this Plan of Merger shall be treated for federal income tax purposes (i) as to Properties LLC, as a complete liquidation of a wholly-owned subsidiary (Properties LLC) into its owner (Pioneer USA) pursuant to Sections 332, 334(b) and 337 of the Internal Revenue Code of 1986, as amended (the “Code”), and (ii) except to the extent provided in (i), as disregarded. With respect to Properties LLC, this Plan of Merger is intended to constitute a plan of complete liquidation in complete cancellation or redemption of all of its membership interests (treated as stock for federal income tax purposes) under Section 332 of the Code.
Federal Tax Treatment. The Program is intended to meet the requirements of a qualified tuition program under Section 529. As such, earnings allocated to Accounts of the Program but not distributed out of the Program are not subject to federal income tax. In order to be eligible for such tax treatment and for Account Owners and Designated Beneficiaries to receive the favorable federal income, estate, gift and generation-skipping tax treatment described below, the Program is required to implement certain restrictions and procedures applicable Contributions. Contributions to an Account do not result in taxable income to the Designated Beneficiary. See discussion under the caption “Federal Gift, Estate and Generation-Skipping Transfer Taxes” below. A contributor may not deduct any contribution from income for purposes of determining federal income taxes. A contribution to an Account for a specific Designated Beneficiary must be rejected to the extent that the amount of the contribution would cause the aggregate amount held in Accounts for that Designated Beneficiary (regardless of Account Owner) to exceed the Maximum Balance Limit discussed under “OPENING AND MAINTAINING YOUR ACCOUNT — Maximum Balance Limit.” This limitation on contributions is intended to comply with the federal tax law requirement that the Program have adequate safeguards to prevent contributions to an Account in excess of those necessary to provide for the reasonably anticipated qualified education expenses of the Designated Beneficiary of the Account. For purposes of this limit, amounts on deposit in all Accounts established under the Program for the same Designated Beneficiary are taken into account, including (i) Accounts established by another Account Owner and (ii) Additional South Dakota Investment Portfolios (that is, accounts established under certain Investment Portfolios provided by the Council that are not offered under this Plan Disclosure Statement but which are considered part of the same “program” for federal tax purposes, as discussed above under “OPENING AND MAINTAINING YOUR ACCOUNT — Maximum Balance Limit”). While not expected, it is possible (i) that, under federal law, a lower limit on the aggregate balance of Accounts for the same Designated Beneficiary might be applicable under certain circumstances and (ii) that a portion of an Account may need to be refunded for the Program to comply with new limits required by federal law, with the earnings component of such refund possibly being subject ...
Federal Tax Treatment. The parties hereto shall have independently determined, in a manner satisfactory to CDXX and PENSAT, as the case may be, that, on the basis of the state of facts existing at the Effective Time, the Merger will be treated as a reorganization within the meaning of Section 368(a) of the Code.
Federal Tax Treatment. The Parties acknowledge that for U.S. federal income tax purposes, the acquisition of the Deep South Shares will be treated as a transfer of the assets of the Deep South Qualified Sub-S Subsidiaries to Buyer, followed by Buyer’s transfer of these assets to the capital of the Deep South Qualified Sub-S Subsidiaries in exchange for the respective stock of the Deep South Qualified Sub-S Subsidiaries.
Federal Tax Treatment. The regulations of the Internal Revenue Service now in effect require a determination of the value of the Warrants of the Company being delivered on the Closing Date. Accordingly, it is therefore agreed by the Company and you that for Federal income tax purposes the amount of the issue price allocated to the Warrants to be issued to you on the date hereof is $52,500, which shall be the value ascribed to such Warrants by the Company, you and any subsequent holder of the Notes or Warrants for all purposes, including the preparation of tax returns and the preparation of the Company's financial statements.
Federal Tax Treatment. For U.S. federal tax purposes, the Reorganization is intended to qualify as a partnership merger within the meaning of Section 708(b)(2) of the Internal Revenue Code of 1986, as amended (the “Code”) and Treas. Reg. § 1.708-1(c)(1). In accordance with Treas. Reg. § 1.708-1(c)(1), (i) the “resulting partnership” shall be treated as a continuation of the Acquiring Fund and (ii) the Acquired Fund shall terminate and its taxable year will close. In accordance with Treas. Reg. § 1.7081(c)(3)(i), the Reorganization will follow the “asset-over form” for U.S. federal tax purposes, pursuant to which, (i) the Acquired Fund will be deemed to contribute all of its assets and liabilities to the Acquiring Fund in exchange for interests in the Acquiring Fund, and (ii) immediately thereafter, the Acquired Fund will be deemed to distribute the interests in the Acquired Fund to its partners in liquidation of the Acquired Fund.
Federal Tax Treatment. For federal income tax purposes, it is intended that the Interim Merger will qualify as a "qualified stock purchase" under Section 338(d) of the Internal Revenue Code of 1986, as amended (the "Code") and that the Bank Merger will qualify as a tax free subsidiary liquidation under Section 332 of the Code, as set forth in Revenue Ruling 90-95, 1990-2 C.B.67. General Bank hereby confirms and agrees, that it shall not, with respect to the Interim Merger, make an election under Section 338 of the Code (or any corresponding provision of state or local law) to have Liberty Bank treated as if it had sold all its assets for federal (and/or state or local) income tax purposes.
