CTB Election definition
Examples of CTB Election in a sentence
The General Partner shall have made the CTB Election in accordance with the procedures set forth in IRS Form 8832 and its instructions.
Except for the effective date of the CTB Election, if a date on which any party is required to take any action under the terms of this Agreement is not a Business Day, the action may be taken on the next succeeding Business Day without penalty.
For U.S. federal (and applicable state and local) income tax purposes, (i) the CTB Election, (ii) the CLMT Merger and (iii) the GP Merger each shall be treated as tax-deferred contributions governed by Section 351 of the Code (and any corresponding provision of state or local law).
From the date of the applicable CTB Election until the date of the Closing, each of SDHC and ndtHost will be properly treated as an entity disregarded as separate from the applicable Seller for U.S. federal income tax purposes.
The parties intend that the acquisition by Newco of the shares of the Company pursuant to the completion of the Offer, followed by the CTB Election, shall together be treated as a reorganization under Section 368(a)(1)(F) of the United States Internal Revenue Code (the “Code”), and that this Agreement shall constitute the “plan of reorganization” within the meaning of Sections 354 and 361 of the Code.