Listed Transactions. Neither the Company nor any Company Subsidiary has entered into any “listed transaction” within the meaning of Treasury Regulation Section 1.6011-4(b)(2).
Listed Transactions. The Company shall not knowingly engage in a transaction that, as of the date the Company enters into a binding contract to engage in such transaction, is a “listed transaction” as defined in Internal Revenue Code Section 6707A(c)(2) and Treas. Reg. § 1.6011-4(b)(2). The Company shall inform the Members if it becomes aware that it has engaged in a transaction that would be a “reportable transaction” as defined in Treas. Reg. § 1.6011-4(b). If a Member is required to make filings in connection with such reportable transaction, the Company will use its reasonable best efforts to forward information necessary to complete such filings and to otherwise assist in such filings.
Listed Transactions. Neither the Company nor any of its Subsidiaries has been a party to, participated in or been a material advisor with respect to, a “listed transaction” within the meaning of Treasury Regulation Section 1.6011-4(b) (or any similar provision of state, local or non-U.S. Law).
Listed Transactions. The Company has not entered into any “listed transaction” or “reportable transaction” within the meaning of Treasury Regulation Section 1.6011-4(b).
Listed Transactions. The Company has not participated or been a “material advisor” or “promoter” (as those terms are or have been defined in Sections 6111 and 6112 of the Code) in: (i) any “listed transaction” within the meaning of Sections 6011, 6662A, and 6707A of the Code (or any corresponding or similar provision of Applicable Tax Law),
Listed Transactions. Neither F Co nor any F Co Subsidiary is required to make any disclosure to the IRS with respect to a "listed transaction" pursuant to Section 1.6011-4(b)(2) of the Treasury Regulations promulgated under the Code.
Listed Transactions. Neither Parent nor any of its Subsidiaries has been a party to, participated in or been a material advisor with respect to, a “listed transaction” within the meaning of Treasury Regulation Section 1.6011-4(b) (or any similar provision of state, local or non-U.S. Law).
Listed Transactions. Neither the Company nor any Subsidiary is required to make any disclosure to the Internal Revenue Service with respect to a “listed transaction” pursuant to Section 1.6011-4(b)(2) of the Treasury Regulations promulgated under the Code.
Listed Transactions. The Company has not participated in a “listed transaction” within the meaning of Treasury Regulations Section 1.6011-4(c) within the last five years.
Listed Transactions. None of the Transferred Entities has participated in a transaction that could affect the Tax liability for any taxable year not closed by the applicable statute of limitations which is a “listed transaction” within the meaning of Section 6707A(c)(2) of the Code and Treasury Regulations Section 1.6011-4(b)(2).
