Treasury Regulation. SECTION 1.848-2(g)(8) JOINT ELECTION --------------------------------------------------------------------- The Company and the Reinsurer hereby agree to the following pursuant to Section 1.848-2(g)(8) of the Income Tax Regulations issued December 1992, under Section 848 of the Internal Revenue Code of 1986, as amended. This election shall be effective for the taxable year ended December 31, 1999 and for all subsequent taxable years for which this Agreement remains in effect unless such election is terminated by mutual written agreement of the parties hereto with the consent, if required, of the Commissioner of the Internal Revenue Service. As used in this Article XV, the term "party" will refer to either the Company or the Reinsurer as appropriate. The terms used in this Article XV are defined by reference to Treasury Regulation Section 1.848-2 in effect as of December 29, 1992. The term "net consideration" will refer to either net consideration as defined in Treasury Regulation Section 1.848-2(f) or "gross premium and other consideration" as defined in Treasury Regulation Section 1.848-2(b) as appropriate. Both parties agree to identify this Agreement as one for which the joint election under Treasury Regulation Section 1.848-2(g)(8) has been made in a schedule attached to their respective federal income tax returns for the taxable period ended December31, 1999. The party with the positive net consideration for this Agreement for each taxable year will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848(c)( 1). Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency or as otherwise required by the Internal Revenue Service. The Company will submit a schedule to the Reinsurer by July 1st of each year of its calculation of the net consideration for the preceding calendar year. This schedule of calculations will be accompanied by a statement signed by an officer of the Company stating that the Company will report such net consideration in its tax return for the preceding calendar year. The Reinsurer may contest such calculation by providing an alternative calculation to the Company in writing within forty-five (45) days of the Reinsurer's receipt of the Company's calculation. If the Reinsurer does not so notify the Company, the Reinsurer will report the net consideration as determi...
Treasury Regulation. 60 TrizecHahn . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1
Treasury Regulation. 7 AGREEMENT OF PURCHASE AND SALE This AGREEMENT OF PURCHASE AND SALE, dated as of March 12, 2007, is made and entered into by and between CMS Enterprises Company, a Michigan corporation, and CMS Energy Investment LLC, a Delaware limited liability company (collectively the "Seller"), and Lucid Energy, L.L.C., a Michigan limited liability company ("Lucid"), and Michigan Pipeline and Processing, LLC, a Michigan limited liability company (collectively the "Buyer").
Treasury Regulation. 5.14(m) Valuation Period..................1.01(b)(v) -iv- 6 AGREEMENT AND PLAN OF MERGER This Agreement and Plan of Merger (the "Agreement"), dated as of September 2, 1996, is by and among Potash Corporation of Saskatchewan Inc., a Saskatchewan corporation ("PCS"), Arcadian Corporation, a Delaware corporation ("Arcadian"), and PCS Nitrogen, Inc., a Delaware corporation and a wholly-owned subsidiary of PCS ("Merger Sub").