structured arrangement definition
structured arrangement means an arrangement involving a hybrid mismatch where the mismatch is priced into the terms of the arrangement or an arrangement that has been designed to produce a hybrid mismatch outcome, unless the taxpayer or an associated enterprise could not reasonably have been expected to be aware of the hybrid mismatch and did not share in the value of the tax benefit resulting from the hybrid mismatch;
structured arrangement means an arrangement involving a transaction, or series of transactions, under which a mismatch outcome arises, where—
structured arrangement means an Arrangement involving a transaction, or series of transactions, under which a Mismatch Outcome arises, where the Mismatch Outcome is priced into the terms of the Arrangement or the Arrangement was designed to give rise to a Mismatch Outcome.
More Definitions of structured arrangement
structured arrangement means two or more transfers/acquisitions of portions of the same property made by the same person within a period of six months which are executed by two or more deeds, rather than by one single deed, solely or mainly for the purpose of inflating the benefit of the exemption.
structured arrangement means an arrangement involving a hybrid mismatch where the mismatch is priced into the terms of the arrangement aorrangement that has
structured arrangement means any transaction, between the Company or any of its Restricted Subsidiaries and another Person, the effects of which include the realization of tax benefits by such other Person