Common use of Private Letter Ruling or Change or Clarification of Law Clause in Contracts

Private Letter Ruling or Change or Clarification of Law. At Developer’s request and expense, Affected Transmission Owner shall file with the IRS a request for a private letter ruling as to whether any property transferred or sums paid, or to be paid, by Developer to Affected Transmission Owner under this Agreement are subject to federal income taxation. Developer will prepare the initial draft of the request for a private letter ruling, and will certify under penalties of perjury that all facts represented in such request are true and accurate to the best of Developer’s knowledge. Affected Transmission Owner and Developer shall cooperate in good faith with respect to the submission of such request. Affected Transmission Owner shall keep Developer fully informed of the status of such request for a private letter ruling and shall execute either a privacy act waiver or a limited power of attorney, in a form acceptable to the IRS, that authorizes Developer to participate in all discussions with the IRS regarding such request for a private letter ruling. Affected Transmission Owner shall allow Developer to attend all meetings with IRS officials about the request and shall permit Developer to prepare the initial drafts of any follow-up letters in connection with the request.

Private Letter Ruling or Change or Clarification of Law. At Developer’s request and expense, Affected Connecting Transmission Owner Owners shall file with the IRS a request for a private letter ruling as to whether any property transferred or sums paid, or to be paid, by Developer to Affected Connecting Transmission Owner Owners under this Agreement are subject to federal income taxation. Developer will prepare the initial draft of the request for a private letter ruling, and will certify under penalties of perjury that all facts represented in such request are true and accurate to the best of Developer’s knowledge. Affected Connecting Transmission Owner Owners and Developer shall cooperate in good faith with respect to the submission of such request. Affected Connecting Transmission Owner Owners shall keep Developer fully informed of the status of such request for a private letter ruling and shall execute either a privacy act waiver or a limited power of attorney, in a form acceptable to the IRS, that authorizes Developer to participate in all discussions with the IRS regarding such request for a private letter ruling. Affected Connecting Transmission Owner Owners shall allow Developer to attend all meetings with IRS officials about the request and shall permit Developer to prepare the initial drafts of any follow-up letters in connection with the request.

Private Letter Ruling or Change or Clarification of Law. At Transmission Developer’s request and expense, Affected Connecting Transmission Owner shall file with the IRS a request for a private letter ruling as to whether any property transferred or sums paid, or to be paid, by Transmission Developer to Affected Connecting Transmission Owner under this Agreement are subject to federal income taxation. Transmission Developer will prepare the initial draft of the request for a private letter ruling, and will certify under penalties of perjury that all facts represented in such request are true and accurate to the best of Transmission Developer’s knowledge. Affected Connecting Transmission Owner and Transmission Developer shall cooperate in good faith with respect to the submission of such request. Affected Connecting Transmission Owner shall keep Transmission Developer fully informed of the status of such request for a private letter ruling and shall execute either a privacy act waiver or a limited power of attorney, in a form acceptable to the IRS, that authorizes Transmission Developer to participate in all discussions with the IRS regarding such request for a private letter ruling. Affected Connecting Transmission Owner shall allow Transmission Developer to attend all SERVICE AGREEMENT NO. 2612 meetings with IRS officials about the request and shall permit Transmission Developer to prepare the initial drafts of any follow-up letters in connection with the request.

Private Letter Ruling or Change or Clarification of Law. At Developer’s request and expense, Affected Connecting Transmission Owner Owners shall file with the IRS a request for a private letter ruling as to whether any property transferred or sums paid, or to be paid, by Developer to Affected Connecting Transmission Owner Owners under this Agreement are subject to federal income taxation. Developer will prepare the initial draft of the request for a private letter ruling, and will certify under penalties of perjury that all facts represented in such request are true and accurate to the best of Developer’s knowledge. Affected Connecting Transmission Owner Owners and Developer shall cooperate in good faith with respect to the submission of such request. Affected Connecting Transmission Owner Owners shall keep Developer fully informed of the status of such request for a private letter ruling and shall execute either a privacy act waiver or a limited power of attorney, in a form acceptable to the IRS, that authorizes Developer to participate in all discussions with the IRS regarding such request for a private letter ruling. Affected Connecting Transmission Owner Owners shall allow Developer to attend all meetings with IRS officials about the request and shall SERVICE AGREEMENT NO. 1757 permit Developer to prepare the initial drafts of any follow-up letters in connection with the request.

Private Letter Ruling or Change or Clarification of Law. At Developer’s request and expense, Affected Transmission Owner shall file with the IRS a request for a private letter ruling as to whether any property transferred or sums paid, or to be paid, by Developer to Affected Transmission Owner under this Agreement are subject to federal income taxation. Developer will prepare the initial draft of the request for a private letter ruling, and will certify under penalties of perjury that all facts represented in such request are true and accurate to the best of Developer’s knowledge. Affected Transmission Owner and Developer shall cooperate in good faith with respect to the submission of such request. Affected Transmission Owner shall keep Developer fully informed of the status of such request for a private letter ruling and shall execute either a privacy act waiver or a limited power of attorney, in a form acceptable to the IRS, that authorizes Developer to participate in all discussions with the IRS regarding such request for a private letter ruling. Affected Transmission Owner shall allow Developer to attend all meetings with IRS officials about the request and shall permit Developer to prepare the initial drafts of any follow-up letters in connection with the request. If the private letter ruling concludes that such transfers or sums are not subject to federal income taxation, or a clarification of or change in law results in Transmission Owner determining in good faith that such transfers or sums are not subject to federal income taxation, Parties’ obligations regarding a gross- up or security under this Article 5.17 shall be reduced accordingly.

Private Letter Ruling or Change or Clarification of Law. At Developer’s request and expense, Affected Connecting Transmission Owner Owners shall file with the IRS a request for a private letter ruling as to whether any property transferred or sums paid, or to be paid, by Developer to Affected Connecting Transmission Owner Owners under this Agreement are subject to federal income taxation. Developer will prepare the initial draft of the request for a private letter ruling, and will certify under penalties of perjury that all facts represented in such request are true and accurate to the best of Developer’s knowledge. Affected Connecting Transmission Owner Owners and Developer shall cooperate in good faith with respect to the submission of such request. Affected Connecting Transmission Owner Owners shall keep Developer fully informed of the status of such request for a private letter ruling and shall execute either a privacy act waiver or a limited power of attorney, in a form acceptable to the IRS, that authorizes Developer to participate in all discussions with the IRS regarding such request for a private letter ruling. Affected Connecting Transmission Owner Owners shall allow Developer to attend all meetings with IRS officials about the request and shall SERVICE AGREEMENT NO. 1757 permit Developer Xxxxxxxxx to prepare the initial drafts of any follow-up letters in connection with the request.

Private Letter Ruling or Change or Clarification of Law. At Transmission Developer’s request and expense, Affected Connecting Transmission Owner shall file with the IRS a request for a private letter ruling as to whether any property transferred or sums paid, or to be paid, by Transmission Developer to Affected Connecting Transmission Owner under this Agreement are subject to federal income taxation. Transmission Developer will prepare the initial draft of the request for a private letter ruling, and will certify under penalties of perjury that all facts represented in such request are true and accurate to the best of Transmission Developer’s knowledge. Affected Connecting Transmission Owner and Developer shall cooperate in good faith with Transmission Developer with respect to the submission of such request. Affected Connecting Transmission Owner shall keep Transmission Developer fully informed of the status of such request for a private letter ruling and shall execute either a privacy act waiver or a limited power of attorney, in a form acceptable to the IRS, that authorizes Transmission Developer to participate in all discussions with the IRS regarding such request for a private letter ruling. Affected Connecting Transmission Owner shall allow Transmission Developer to attend all meetings with IRS officials about the request and shall permit Transmission Developer to prepare the initial drafts of any follow-up letters in connection with the request.

Private Letter Ruling or Change or Clarification of Law. At Developer’s request and expense, Affected Transmission Owner shall file with the IRS a request for a private letter ruling as to whether any property transferred or sums paid, or to be paid, by Developer to Affected Transmission Owner under this Agreement are subject to federal income taxation. Developer will prepare the initial draft of the request for a private letter ruling, and will certify under penalties of perjury that all facts represented in such request are true and accurate to the best of Developer’s knowledge. Affected Transmission Owner and Developer shall cooperate in good faith with respect to the submission of such request. Affected Transmission Owner shall keep Developer fully informed of the status of such request for a private letter ruling and shall execute either a privacy act waiver or a limited power of attorney, in a form acceptable to the IRS, that authorizes Developer to participate in all discussions with the IRS regarding such request for a private letter ruling. Affected Transmission Owner shall allow Developer to attend all meetings with IRS officials about the request and shall permit Developer to prepare the initial drafts of any follow-up letters in connection with the request. If the private letter ruling concludes that such trans fers or sums are not subject to federal income taxation, or a clarification of or change in law results in Transmission Owner determining in good faith that such transfers or sums are not subject to federal income taxation, Parties’ obligations regarding a gross- up or security under this Article 5.17 shall be reduced accordingly.

Private Letter Ruling or Change or Clarification of Law. At Transmission Developer’s request and expense, Affected Connecting Transmission Owner shall file with the IRS a request for a private letter ruling as to whether any property transferred or sums paid, or to be paid, by Transmission Developer to Affected Connecting Transmission Owner under this Agreement are subject to federal income taxation. Transmission Developer will prepare the initial draft of the request for a private letter ruling, and will certify under penalties of perjury that all facts represented in such request are true and accurate to the best of Transmission Developer’s knowledge. Affected Connecting Transmission Owner and Transmission Developer shall cooperate in good faith with respect to the submission of such request. Affected Connecting Transmission Owner shall keep Transmission Developer fully informed of the status of such request for a private letter ruling and shall execute either a privacy act waiver or a limited power of attorney, in a form acceptable to the IRS, that authorizes Transmission Developer to participate in all discussions with the IRS regarding such request for a private letter ruling. Affected Connecting Transmission Owner shall allow Transmission Developer to attend all SERVICE AGREEMENT NO. 2611 meetings with IRS officials about the request and shall permit Transmission Developer to prepare the initial drafts of any follow-up letters in connection with the request.

Private Letter Ruling or Change or Clarification of Law. At Developer’s request and expense, Affected Connecting Transmission Owner OwnerAffected System Operator shall file with the IRS a request for a private letter ruling as to whether any property transferred or sums paid, or to be paid, by Developer to Affected Connecting Transmission Owner OwnerAffected System Operator under this Agreement are subject to federal income taxation. Developer will prepare the initial draft of the request for a private letter ruling, and will certify under penalties of perjury that all facts represented in such request are true and accurate to the best of Developer’s knowledge. Affected Connecting Transmission Owner OwnerAffected System Operator and Developer shall cooperate in good faith with respect to the submission of such request. Affected Connecting Transmission Owner OwnerAffected System Operator shall keep Developer fully informed of the status of such request for a private letter ruling and shall execute either a privacy act waiver or a limited power of attorney, in a form acceptable to the IRS, that authorizes Developer to participate in all discussions with the IRS regarding such request for a private letter ruling. Affected Connecting Transmission Owner OwnerAffected System Operator shall allow Developer to attend all meetings with IRS officials about the request and shall permit Developer to prepare the initial drafts of any follow-up letters in connection with the request.

Private Letter Ruling or Change or Clarification of Law. At any Developer’s request and expense, Affected ConnectingAffected Transmission Owner shall file with the IRS a request for a private letter ruling as to whether any property transferred or sums paid, or to be paid, by the Developer to Connectingthe Affected Transmission Owner under this Agreement are subject to federal income taxation. The Developer will prepare the initial draft of the request for a private letter ruling, and will certify under penalties of perjury that all facts represented in such request are true and accurate to the best of the Developer’s knowledge. ConnectingThe Affected Transmission Owner and the Developer shall cooperate in good faith with respect to the submission of such request. ConnectingThe Affected Transmission Owner shall keep the Developer fully informed of the status of such request for a private letter ruling and shall execute either a privacy act waiver or a limited power of attorney, in a form acceptable to the IRS, that authorizes the Developer to participate in all discussions with the IRS regarding such request for a private letter ruling. ConnectingThe Affected Transmission Owner shall allow the Developer to attend all meetings with IRS officials about the request and shall permit the Developer to prepare the initial drafts of any follow-up letters in connection with the request.

Private Letter Ruling or Change or Clarification of Law. At Developer’s request and expense, Affected Transmission Owner shall file with the IRS a request for a private letter ruling as to whether any property transferred or sums paid, or to be paid, by Developer to Affected Transmission Owner under this Agreement are subject to federal income taxation. Developer will prepare the initial draft of the request for a private letter ruling, and will certify under penalties of perjury that all facts represented in such request are true and accurate to the best of DeveloperXxxxxxxxx’s knowledge. Affected Transmission Owner and Developer shall cooperate in good faith with respect to the submission of such request. Affected Transmission Owner shall keep Developer fully informed of the status of such request for a private letter ruling and shall execute either a privacy act waiver or a limited power of attorney, in a form acceptable to the IRS, that authorizes Developer to participate in all discussions with the IRS regarding such request for a private letter ruling. Affected Transmission Owner shall allow Developer to attend all meetings with IRS officials about the request and shall permit Developer to prepare the initial drafts of any follow-up letters in connection with the request.