IRS Letter Ruling definition

IRS Letter Ruling means an IRS private letter ruling, dated August 2, 2002, setting forth IRS rulings regarding certain Tax consequences of the Distribution and certain related transactions, together with any supplemental private letter rulings issued with respect thereto.
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IRS Letter Ruling means the private letter ruling Ref. No. PLR-168887-01 issued by the IRS to Allergan and dated May 15, 2002.
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IRS Letter Ruling means a private letter ruling from the IRS ruling that, among other things, the Merger will qualify as a reorganization under Section 368(a) of the Code.
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Examples of IRS Letter Ruling in a sentence

  • The tax regulations do not specifically provide a formal method for computing what this portion is; however, IRS Letter Ruling 8213102 indicates a method of calculating a medical expense percentage by using the ratio of medical expenses to all expenses of the Community.

  • The fact that I can do something or think that I can do something without being caught does not make it right to do so.

  • At no time during the Term or Renewal Term shall the Contractor seek an IRS Letter Ruling, SEC No-Action Letter or any other interpretation of Applicable Law by any Governmental Authority specifically relating to the Program independent of the efforts of the Agency to obtain such interpretations and without the express written consent of the Agency, which consent shall not be unreasonably withheld to the extent consistent with the Program.(c) Actions; Expenses.

  • Also, Parent will pay all the fees, costs and expenses associated with obtaining the IRS Letter Ruling.

  • The parties will cooperate with each other in a commercially reasonable manner in order that the conditions to the obligations of the Agency and the Contractor contained in Section 10 are satisfied and the duties and obligations of the parties hereunder may be effectively, efficiently and promptly discharged.(b) IRS Letter Ruling; SEC No-Action Letter.

  • Very truly yours, FIRST CLASS NAVIGATION CORPORATION By: Xxxxxxxxx X.

  • IRS Letter Ruling 201021048; 6/7/2010The IRS has privately ruled that the treatment of a taxpayer and his domestic partner’s earnings as community property did not result in a transfer of property between the couple for purposes of the federal gift tax.

  • IRS Letter Ruling 201721014 permits a holding company to reorganize on a tax-free basis by swapping out old shares for new shares and then liquidating.27 By swapping Privateer’s old Tilray shares, and replacing them with newly issued Tilray shares and then redistributing the newly issued shares to Privateer’s equity holders, the Company may ensure that the IRS will treat the share cancellation and 26 TILRAY_220_0000277 (emphasis added).

  • IRS Letter Ruling 200552007, December 30, 2005: “In most instances, a shareholder in a publicly traded corporation is unlikely to control the corporation even through attribution.

  • IRS Letter Ruling 201011002The modification and division of three (3) irrevocable trusts into separate and equal trusts did not cause the trusts to lose their exempt status for generation-­‐skipping transfers (GST) tax purposes under Section 2601.


More Definitions of IRS Letter Ruling

IRS Letter Ruling means the private letter ruling Xxx Xx. XXX-x00000-00 issued by the IRS to Allergan and dated May 15, 2002.
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Related to IRS Letter Ruling

  • Private Letter Ruling shall have the meaning set forth in the Recitals.

  • IRS Ruling shall have the meaning set forth in the Recitals.

  • Tax Ruling as used in this Agreement, shall mean a written ruling of a taxing authority relating to Taxes. "Closing Agreement", as used in this Agreement, shall mean a written and legally binding agreement with a taxing authority relating to Taxes.

  • Supplemental Ruling means (i) any ruling (other than the Ruling) issued by the IRS in connection with a Distribution, and (ii) any similar ruling issued by any other Taxing Authority addressing the application of a provision of the laws of another jurisdiction to a Distribution.

  • closing agreement as described in Section 7121 of the Code (or any corresponding or similar provision of state, local or foreign income Tax law) executed on or prior to the Closing Date; (iii) installment sale or open transaction disposition made on or prior to the Closing Date; or (iv) prepaid amount received on or prior to the Closing Date;

  • Ruling Request means any letter filed by Parent with the IRS or other Tax Authority requesting a ruling regarding certain tax consequences of any of the Separation Transactions (including all attachments, exhibits, and other materials submitted with such ruling request letter) and any amendments or supplements to such ruling request letter.

  • advance ruling means a decision provided by the Authority or the Appellate Authority to an applicant on matters or on questions specified in sub-section (2) of section 97 or sub-section (1) of section 100, in relation to the supply of goods or services or both being undertaken or proposed to be undertaken by the applicant;

  • IRS means the United States Internal Revenue Service.

  • Tax Regulatory Agreement means the Tax Regulatory Agreement, dated as of the date of initial issuance and delivery of the Bonds, among the Authority, the Borrower and the Trustee, and any amendments and supplements thereto.

  • Tax Counsel shall have the meaning set forth in Section 6.2 hereof.

  • Advance Ruling Certificate means an advance ruling certificate issued by the Commissioner of Competition pursuant to section 102 of the Competition Act with respect to the transactions contemplated by this Agreement.

  • Tax Opinion means, with respect to any action, an Opinion of Counsel to the effect that, for federal income tax purposes, (a) such action will not cause the Notes of any outstanding class of Notes that were characterized as debt at the time of their issuance to be characterized as other than debt, (b) such action will not cause the Trust to be deemed to be an association (or publicly traded partnership) taxable as a corporation and (c) such action will not cause or constitute an event in which gain or loss would be recognized by any Holder.

  • Tax Opinions mean certain Tax opinions and supporting memoranda rendered by Bxxxxxxxx to RemainCo or any of its Affiliates in connection with the Plan of Separation.

  • Tax Opinions/Rulings means (i) any Ruling and (ii) any opinion of a Tax Advisor relating to the Transactions, including those issued on the Distribution Date or to allow a party to take actions otherwise prohibited under Section 4.03(a) of this Agreement.

  • Alternative Acquisition Agreement shall have the meaning set forth in Section 6.5(c).

  • Tax Matters Agreement means the Tax Matters Agreement to be entered into by and between Parent and SpinCo or any members of their respective Groups in connection with the Separation, the Distribution or the other transactions contemplated by this Agreement, as it may be amended from time to time.

  • Ruling Documents means the Ruling and the Ruling Request.

  • Post-Closing Agreement shall have the meaning set forth in Section 8.9.

  • Tax Certification Forms means any forms or other documentation as may be issued or required by a Tax Authority or by us from time to time to confirm your tax status [or the tax status of a Connected Person].

  • Representation Letters means the representation letters and any other materials (including, without limitation, a Ruling Request and any related supplemental submissions to the IRS) delivered or deliverable by, or on behalf of, Parent, SpinCo and others in connection with the rendering by Tax Advisors and/or the issuance by the IRS of the Tax Opinions/Rulings.

  • Favorable Opinion of Bond Counsel means an opinion of Bond Counsel addressed to the Issuer and the Trustee to the effect that the action proposed to be taken is authorized or permitted by the laws of the Commonwealth and this Indenture and will not, in and of itself, adversely affect any exclusion of interest on the Bonds from gross income of the owners thereof for federal income tax purposes.

  • Sponsor Letter Agreement has the meaning set forth in the recitals to this Agreement.

  • Company Acquisition Agreement has the meaning set forth in Section 5.04(a).

  • Transition Agreement means the Transition Power Sales Agreement dated as of November 24, 1998, by and between Seller, Southern Energy, Southern Energy Bowline, L.L.C. and Southern Energy Xxxxxx, L.L.C.

  • Company Counsel means Xxxxxxxx LLP, with offices located at 000 Xxxxx Xxxxxx Xxx, Xxxxx 000, Xxxxxxxxx, Xxxxxxxx 00000.

  • Tax Allocation Agreement means the Tax Allocation Agreement between Corporation and New D&B.