Internal Distributions definition

Internal Distributions means the First Internal Distribution, the Second Internal Distribution, and the Third Internal Distribution.

Internal Distributions means the distributions of SPINCO common stock by Teledyne Industries, Inc. to TDY Holdings, LLC, a Delaware limited liability company wholly owned by ATI, and by TDY Holdings, LLC to ATI. IRS means the U.S. Internal Revenue Service.

Internal Distributions means the distributions of stock within the Remainco Existing Group that are described in the US Ruling as qualifying for nonrecognition treatment under Sections 355 and 368(a)(1)(D) of the Code;

Examples of Internal Distributions in a sentence

• This Section 5.7(a) is intended to constitute binding, written agreements to make elections under Section 336(e) of the Code with respect to the Internal Distributions.

• YUM and the SpinCo Parties shall each file, or cause the applicable members of the YUM Group or the SpinCo Group, respectively, to file, any Tax Returns (for the avoidance of doubt, including any Tax reporting filings) that are mandatorily required by SAT Bulletin 7 to be filed by such Person with respect to the Distribution and the Internal Distributions.

• Subject to the conditions and other terms set forth in this Article IV, on the Distribution Date, Parent shall cause the Distribution Agent to make the Distribution, effective as of the Effective Time, of all SpinCo Common Stock held by Parent after the Internal Distributions, including by crediting the appropriate number of shares of SpinCo Common Stock to book-entry accounts for each Record Holder or designated transferee or transferees of such Record Holder.

• COSMOmic: A Mechanistic Approach to the Calculation of Membrane-Water Partition Coefficients and Internal Distributions within Membranes and Micelles.

• Each of Burgundy, Spinco and Grizzly represents and warrants that it knows of no fact (after due inquiry) that may cause the Tax treatment of the Spinco Reorganization, the Internal Contributions, the Internal Distributions, the Contribution or the Distribution to be other than the Tax-Free Status of the Transactions.

More Definitions of Internal Distributions

Internal Distributions means the separation of (a) the UTC Assets and UTC Liabilities from the Carrier Assets and Carrier Liabilities and/or the Otis Assets and Otis Liabilities, (b) the Carrier Assets and Carrier Liabilities from the UTC Assets and UTC Liabilities and/or the Otis Assets and Otis Liabilities, and/or (c) the Otis Assets and Otis Liabilities from the UTC Assets and UTC Liabilities and/or the Carrier Assets and Carrier Liabilities, in each case, (i) held by certain subsidiaries of UTC and (ii) in a transaction intended to qualify, for Federal Income Tax purposes, as a distribution that is generally tax-free pursuant to Section 355(a) (or Sections 355(a) and 368(a)(1)(D)) of the Code.

Internal Distributions has the meaning set forth in the Recitals.

Internal Distributions has the meaning set forth in the Tax Matters Agreement.

Internal Distributions shall have the meaning set forth in the recitals hereto.

Internal Distributions means the transactions described in Schedule B.

Internal Distributions shall have the meaning set forth in Section 3.1.

Internal Distributions means an Institution’s internal distributions to inventors, investigators, divisions, departments or others within the Institution.