IRS Ruling Request definition

IRS Ruling Request means the letter filed by Xxxxxxxxx with the IRS requesting a ruling regarding certain U.S. federal income tax consequences of the Transactions and any amendment or supplement to such ruling request letter.

IRS Ruling Request means the letter filed by Parent with the IRS requesting a ruling regarding certain tax consequences of the Transactions and any amendment or supplement to such ruling request letter.

IRS Ruling Request means the request for private letter rulings filed by UTC on July 31, 2019 with the IRS (including all attachments, exhibits, and other materials submitted with such ruling request letter) and any amendments or supplements to such request.

Examples of IRS Ruling Request in a sentence

• Starwood may, in its discretion, submit an IRS Ruling Request to the IRS regarding an SVO Conversion.

• Such opinion shall be issued on the basis of customary representations, assumptions (including the accuracy of the IRS Ruling Request, as amended or supplemented through the date of such opinion, and the accuracy and continuing validity of the IRS Ruling) and undertakings set forth or referred to in such opinion and in the related External Spin-Off Tax Representation Letters.

• From and after the date of this Agreement and until the Effective Time, each party hereto agrees to use its reasonable best efforts to facilitate receipt by UTC of the IRS Ruling, including providing such appropriate information as the IRS shall require in connection with the IRS Ruling Request or any IRS Submission.

• In furtherance of the foregoing, to the extent necessary to reflect any such alternative, UTC shall submit one or more IRS Submissions to modify the IRS Ruling Request.

• We express no opinion on any issue or matter relating to the tax consequences of the transactions contemplated by the Merger Agreement, the Distribution Agreement, the other Transaction Agreements, the Registration Statement or the IRS Ruling Request other than the opinion set forth above.

More Definitions of IRS Ruling Request

IRS Ruling Request means any letter filed by Parent with the IRS requesting a ruling regarding certain tax consequences of the Transactions and any amendment or supplement to such ruling request letter.

IRS Ruling Request means the request for private letter rulings filed by Parent on February 16, 2021 with the IRS (including all attachments, exhibits, and other materials submitted with such ruling request and any amendments or supplemental submissions related thereto).

IRS Ruling Request means the request for the IRS Ruling that will be submitted by the Company to the IRS.

IRS Ruling Request means any letter (or other document) filed by IP with the IRS in connection with the IRS Ruling, and any amendment or supplement thereto.

IRS Ruling Request means the letter filed by Parent with the IRS on March 31, 2023, requesting a ruling regarding certain U.S. federal income tax consequences of the Separation and Distribution and any amendment or supplement to such ruling request letter.

IRS Ruling Request means any letter filed by Starwood with the IRS requesting a ruling regarding certain tax consequences of the Restructuring and the Distribution and any amendment or supplement to such ruling request letter.

IRS Ruling Request means the letter filed by Labcorp with the IRS requesting a ruling regarding certain U.S. federal income tax consequences of the Transactions and any amendment or supplement to such ruling request letter received by Labcorp prior to the Distribution Date.