Deferred Intercompany Transaction definition
Examples of Deferred Intercompany Transaction in a sentence
Schedule 3.8 of the Disclosure Schedule sets forth the following information with respect to the Company as of its Most Recent Fiscal Year End: (1) its Tax basis in its assets; (2) the amount of any net operating loss, net capital loss, unused investment credit, unused foreign Tax or excess charitable contribution allocable to it; and (3) the amount of any deferred gain or loss allocable to it arising out of any Deferred Intercompany Transaction.
As of December 31, 2000: (A) the basis of JDC in its assets is $2,233,656; (B) the basis of Company in its stock in JDC (or the amount of any Excess Loss Account as that term is defined in Treasury Regulation Section 1.1502-19) is $2,233,656; and (C) the amount of any deferred gain or loss allocable to JDC arising out of any Deferred Intercompany Transaction as that term is defined in Treasury Regulation Section 1.1502-13) is Zero.
As of the Closing, there shall be no deferred gain or loss allocable to any Company arising out of any Deferred Intercompany Transaction (as defined in Treas.
Section 1.1502-20; (iv) the amount of any net operating loss, net capital loss, unused investment or other credit, unused foreign Tax, or excess charitable contribution allocable to Diagnostics or its Subsidiary; and (iv) the amount of any deferred gain or loss allocable to Diagnostics or its Subsidiary arising out of any Deferred Intercompany Transaction and the amount of any undistributed earnings and profits of Diagnostics and its Subsidiaries immediately prior to Closing as defined under Treas.
In addition, if not set forth in Section 4.11(g) of the Disclosure Schedule, within a reasonable time after the Closing, the Seller will supply the Buyer with a schedule setting forth the amount of any deferred gain or loss allocable to the Company or Subsidiary arising out of any Deferred Intercompany Transaction.