RMT Partner definition
Examples of RMT Partner in a sentence
For the avoidance of doubt, the presence of a Post-Distribution Ruling or Unqualified Tax Opinion shall not relieve SpinCo or RMT Partner from any indemnification obligations otherwise present under this Agreement.
From and after the date of the signing of the Separation and Distribution Agreement, neither RMT Partner, SpinCo nor any of their Affiliates shall file a Ruling Request or otherwise seek any guidance from the IRS or any other Tax Authority (whether written, verbal or otherwise) at any time concerning the Restructuring or the Distribution without the written consent of the Additional ▇▇▇▇▇ Parties.
Any foreign tax credits or deductions under U.S. Tax Law claimed by RMT Partner, its Affiliates, or any member of the SpinCo Group as a result of any CFC Taxes for the Pre-Distribution Period (as determined pursuant to Section 2.3) shall be treated as Tax Benefits corresponding to such CFC Taxes.
SpinCo and RMT Partner shall provide a copy of the Post-Distribution Ruling or the Unqualified Tax Opinion described in this paragraph to Parent as soon as practicable prior to taking or failing to take any action set forth in the foregoing clauses (a) through (i).
As of the Effective Time, this Agreement shall be binding on RMT Partner and RMT Partner shall be subject to the obligations and restrictions imposed on SpinCo hereunder and, for the avoidance of doubt, any restrictions applicable to SpinCo shall apply to RMT Partner, mutatis mutandis.
From and after the date of the signing of the Separation and Distribution Agreement, RMT Partner acknowledges and agrees that the Additional ▇▇▇▇▇ Parties may file (or cause any Affiliate to file) one or more Ruling Requests.