Section 336(e) Election definition
Examples of Section 336(e) Election in a sentence
To the extent a Section 336(e) Election becomes effective, each Party agrees not to take any position (and to cause each of its Affiliates not to take any position) that is inconsistent with the Section 336(e) Election on any Tax Return, in connection with any Tax Contest or otherwise, except as may be required by a Final Determination.
If a Section 336(e) Election is made with respect to the Transactions, then this Agreement shall be amended in such a manner as is determined by Parent in good faith to take into account such Section 336(e) Election(s).
If such Section 336(e) Election is made, this Agreement shall be amended in such a manner as is determined by Medtronic in its good faith discretion to compensate Medtronic for any tax benefits realized by SplitCo as a result of such Section 336(e) Election.