External Spin definition

External Spin means the distribution to the holders of shares of RemainCo common stock of all of the outstanding shares of SpinCo common stock.
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External Spin means the Contribution and Distribution, taken together.
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Examples of External Spin in a sentence

  • Although ▇▇▇▇▇▇▇▇ intends to effect the External Spin, the parties agree that ▇▇▇▇▇▇▇▇ is under no obligation to effect the External Spin at any time.

  • The parties shall attempt in good faith to take reasonable action or reasonably refrain from taking action to ensure the continued qualification of the Internal Spin and the External Spin under the foregoing sections of the Code.

  • This Section 4.2(c) shall not apply as to any matters or transactions with respect to which the IRS has issued (i) a private letter ruling to ▇▇▇▇▇▇▇▇ or WPX or (ii) other guidance that can be relied upon conclusively to the effect that the transaction or event at issue does not adversely affect the Internal Spin or the External Spin under Section 355 or Section 368(a)(1)(D) of the Code.

  • If ▇▇▇▇▇▇▇▇ is required under the Code to allocate to the WPX Group or any of its members any carryovers of any losses, credits or other Tax Attributes to periods following the External Spin, ▇▇▇▇▇▇▇▇ shall not be entitled to reimbursement from WPX by reason of such carryover.

  • The parties shall attempt in good faith to take reasonable action or reasonably refrain from taking action to ensure the continued qualification of the Internal Spin and External Spin under the foregoing sections of the Code.

  • This Section 4.3(c) shall not apply as to any matters or transactions with respect to which the IRS has issued (i) a private letter ruling to ▇▇▇▇▇▇▇▇ or WPX or (ii) other guidance that can be relied upon conclusively to the effect that the transaction or event at issue does not adversely affect the Internal Spin or External Spin under Section 355 or Section 368(a)(1)(D) of the Code.

  • This Section 4.3(c) shall not apply as to any matters or transactions with respect to which the IRS has issued (i) a private letter ruling to ▇▇▇▇▇▇▇▇ or WPX or (ii) other guidance that can be relied upon conclusively to the effect that the transaction or event at issue does not adversely affect the Internal Spin or the External Spin under Section 355 or Section 368(a)(1)(D) of the Code.