No Recognition Opinion definition

No Recognition Opinion means an opinion of a nationally recognized independent tax counsel experienced in such matters, which opinion may rely on published revenue rulings of the Internal Revenue Service, to the effect that the holders of the Capital Securities and Common Securities will not recognize any gain or loss for United States federal income tax purposes as a result of the dissolution of the Trust and the distribution of the Notes.

No Recognition Opinion has the meaning specified in the Declaration.

No Recognition Opinion has the meaning specified in Annex I to the Declaration.

Examples of No Recognition Opinion in a sentence

• Except as set ------------------------------------------------- forth in paragraph (d) of this Section 6.1, upon the occurrence of a Trust Event or a Partnership Event, if the Company cannot obtain a No Recognition Opinion with regard to the distribution of either the Partnership Preferred Securities or the Debentures, then the Company shall have the right to redeem the Debentures, in whole or in part, for cash, at the Redemption Price in accordance with Section 6.4.

• At any time, the Company may elect to cause the dissolution of the trust and the distribution of the Debentures (a "Voluntary Distribution") by delivery of notice to the Regular Trustees of such election, which notice shall be accompanied by a No Recognition Opinion.

• At any time, the Company may elect to cause the dissolution of the Trust and the distribution of the Debentures (a "Voluntary Distribution") by delivery of notice to the Regular Trustees of such election, which notice shall be accompanied by a No Recognition Opinion.

More Definitions of No Recognition Opinion

No Recognition Opinion has the meaning specified in Section 9.04(d).

No Recognition Opinion means an opinion of a nationally recognized independent tax counsel experienced in such matters, which opinion may rely on any then applicable published revenue ruling of the Internal Revenue Service, to the effect that the holders of the Preferred Securities will not recognize any gain or loss for United States federal income tax purposes as a result of a dissolution of the Trust and distribution of the Securities as provided in the Declaration of Trust.

No Recognition Opinion has the meaning set forth in Section 4 of Annex I ---------------------- hereto.

No Recognition Opinion has the meaning set forth in Section 4(c) of Exhibit A hereto.

No Recognition Opinion with respect to a Citigroup Trust, has the meaning specified in the Declaration of such Citigroup Trust.

No Recognition Opinion has the meaning set forth in Exhibit A.

No Recognition Opinion has the meaning set forth in paragraph 4(c) of Annex I.