IRS Ruling definition

IRS Ruling means any U.S. federal income tax ruling and any supplements thereto issued to Parent by the IRS in connection with the Transactions.
IRS Ruling shall have the meaning set forth in the Recitals.
IRS Ruling has the meaning set forth in the recitals to this Agreement.

Examples of IRS Ruling in a sentence

  • All of the foregoing documents contemplated by this Section 2.1(b)(i) and (ii) (including any documents entered into between or among any of the Parties or members of their respective Groups to implement, in furtherance of or in connection with the Reorganization Step Plan prior to the date hereof but excluding, for the avoidance of doubt, the IRS Ruling) shall be referred to collectively herein as the “Transfer Documents”.

  • Mercury shall submit to the IRS supplemental materials relating thereto that Mercury determines in good faith are necessary or appropriate to obtain the requested rulings under the IRS Ruling Request or any additional rulings from the IRS that Mercury determines are necessary or appropriate, including as a result of the transactions contemplated by this Agreement (each, together with the IRS Ruling Request and IRS Pre-Submission Conference Request, an “IRS Submission”).

  • Mercury shall provide Gold with notice reasonably in advance of any formally scheduled meetings (including telephonic meetings) with the IRS (subject to approval by the IRS) that relate to the IRS Ruling Request and any other IRS Submission and permit ▇▇▇▇’s Tax Counsel to attend such meeting if Gold’s Tax Counsel is available during the scheduled time (which scheduled time shall be at the mutual convenience of ▇▇▇▇▇▇▇’s Representatives and the IRS).


More Definitions of IRS Ruling

IRS Ruling shall have the meaning set forth in Section 3.3(a)(i).
IRS Ruling means the private letter ruling (together with any supplements) issued by the IRS in respect of the Ruling Request.
IRS Ruling means any U.S. federal income Tax ruling and any supplements thereto, issued to ▇▇▇▇▇▇▇ by the IRS in connection with the Transactions, the Separation and any related transactions.
IRS Ruling. The letter ruling issued by the IRS in response to the Ruling Request.
IRS Ruling shall have the meaning set forth in Section 2.1(b)(i).
IRS Ruling has the meaning set forth in the Tax Matters Agreement.
IRS Ruling means a private letter ruling from the IRS regarding such matters germane to the U.S. federal income Tax consequences of the Separation, Contribution, Distribution and Merger and any related transactions as the Company may determine in good faith consultation with Parent.