Qualified Tax Status and Tax Responsibilities. The Settlement Fund shall be established as a Qualified Settlement Fund within the meaning of Section 468B of the Internal Revenue Code of 1986, as amended, and Treas. Reg. Section 1.468B-1, et seq., and shall be administered by the Claims Administrator under the Court’s supervision. Defendants shall hereby be deemed to have made an election under Section 468B of the Revenue Code to have the Fund treated as a “Qualified Settlement Fund.” Defendants shall timely furnish a statement to the Trustee that complies with Treasury Regulation § 1.468B-3(e) and shall attach a copy of the statement to its federal income tax return that is filed for the taxable year in which Defendants make the required payment(s) to the Settlement Fund. The parties shall cooperate to ensure such treatment and shall not take a position in any filing or before any tax authority inconsistent with such treatment.
Appears in 2 contracts
Samples: Settlement Agreement, Settlement Agreement
Qualified Tax Status and Tax Responsibilities. The Settlement Fund shall be established as a Qualified Settlement Fund within the meaning of Section 468B of the Internal Revenue Code of 1986, as amended, and Treas. Reg. Section 1.468B-1, et seq., and shall be administered by the Claims Settlement Administrator under the Court’s supervision. Defendants shall hereby be deemed to have made an election under Section 468B of the Revenue Code to have the Fund treated as a “Qualified Settlement Fund.” Defendants shall timely furnish a statement statements to the Trustee Settlement Administrator that complies comply with Treasury Regulation § 1.468B-3(e) and shall attach a copy of the statement statements to its their federal income tax return that is are filed for the taxable year in which Defendants make the required payment(s) to the Settlement Fund. The parties Parties shall cooperate to ensure such treatment and shall not take a position in any filing or before any tax authority inconsistent with such treatment.
Appears in 1 contract
Samples: Stipulation and Agreement
Qualified Tax Status and Tax Responsibilities. The Settlement Fund shall be established as a Qualified Settlement Fund within the meaning of Section 468B of the Internal Revenue Code of 1986, as amended, and Treas. Reg. Section 1.468B-1, et seq., and shall be administered by the Claims Administrator under the Court’s supervision. Defendants Defendant shall hereby be deemed to have made an election under Section 468B of the Revenue Code to have the Fund treated as a “Qualified Settlement Fund.” Defendants Defendant shall timely furnish a statement to the Trustee Claims Administrator that complies with Treasury Regulation § 1.468B-3(e) and shall attach a copy of the statement to its federal income tax return that is filed for the taxable year in which Defendants make Defendant makes the required payment(s) to the Settlement Fund. The parties shall cooperate to ensure such treatment and shall not take a position in any filing or before any tax authority inconsistent with such treatment.
Appears in 1 contract
Samples: General Release Agreement