Tax Counsel No Adverse Effect Opinion definition

Tax Counsel No Adverse Effect Opinion means an opinion of Tax Counsel substantially to the effect that the taking of the action specified therein will not, in and of itself, adversely affect any exclusion of interest on the Governmental Lender Note from gross income for purposes of federal income taxation (subject to the inclusion of such customary exceptions as are acceptable to the recipient thereof).
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Tax Counsel No Adverse Effect Opinion means an opinion of Tax Counsel to the effect that the taking of the action specified therein will not impair the exclusion of interest on the Governmental Lender Note from gross income for purposes of federal income taxation (subject to the inclusion of such customary exceptions as are acceptable to the recipient thereof).
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Tax Counsel No Adverse Effect Opinion means an opinion of Tax Counsel to the effect that the taking of the action specified therein will not impair the exclusion of interest on the Bonds from gross income for purposes of federal income taxation from the holder thereof except for a “substantial user” or “related person” as defined in Section 147(a) of the Code (subject to the inclusion of such customary exceptions as are acceptable to the recipient thereof).
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Examples of Tax Counsel No Adverse Effect Opinion in a sentence

  • In complying with the foregoing covenants, the Governmental Lender may rely from time to time on a Tax Counsel No Adverse Effect Opinion or other appropriate opinion of Tax Counsel.

  • Notwithstanding anything in this Funding Loan Agreement to the contrary, no additional amounts of the Funding Loan may be drawn down and funded hereunder after December 31, 2025 provided, however, that upon the delivery of a Tax Counsel No Adverse Effect Opinion to the Governmental Lender and the Funding Lender such date may be changed to a later date as specified in such Tax Counsel No Adverse Effect Opinion.


More Definitions of Tax Counsel No Adverse Effect Opinion

Tax Counsel No Adverse Effect Opinion means an opinion of Tax Counsel to the effect thatthe talking of the action specified therein wil I nct, in and of itself, adversely affect any exclusion of interest on the G avernmental Lender N ates from gross income for purposes of federal income taxation (subject to the inclusion of such customary excep:ions as are acceptalle to the reci pi ent thereof).
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Tax Counsel No Adverse Effect Opinion means an opinion of Tax Counsel to the effect that the taking of the action specified therein wil not impair the exclusion of T-27388.001 /1127885.doc Council Agenda: 9-9-2014 Item No.: 3.5 interest on the Tax-Exempt Governmental Lender Notes from gross income of the owners thereof for purposes of federal income taxation, except no statement need be made with respect to any Tax-Exempt Governmental Lender Note during any period while such Tax-Exempt Governmental Lender Note is owned by a "substantial user" of the facilities financed by the Tax-Exempt Governmental Lender Notes or a "related person" within the meaning of section 147(a) of the Code (and in any event subject to the inclusion of such other customary exceptions as are acceptable to the recipient thereof).
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Tax Counsel No Adverse Effect Opinion means an opinion of Tax Counsel substantially to the effect that the taking of the action specified therein will not, in and of itself, adversely affect any exclusion of interest on the Governmental Lender Note from gross income
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Related to Tax Counsel No Adverse Effect Opinion

  • Company Material Adverse Effect means any material adverse effect with respect to the Company, taken as a whole, or any change or effect that adversely, or is reasonably expected to adversely, affect the ability of the Company to maintain its current business operations or to consummate the transactions contemplated by this Agreement in any material respect.

  • SPAC Material Adverse Effect (a) any change in applicable Laws or GAAP or any interpretation thereof following the date of this Agreement, (b) any change in interest rates or economic, political, business or financial market conditions generally, (c) the taking or refraining from taking of any action required to be taken or refrained from being taken under this Agreement, (d) any natural disaster (including hurricanes, storms, tornados, flooding, earthquakes, volcanic eruptions or similar occurrences), epidemic or pandemic (including any COVID-19 Measures or any change in such COVID-19 Measures or interpretations following the date of this Agreement), acts of nature or change in climate, (e) any acts of terrorism or war, the outbreak or escalation of hostilities, geopolitical conditions, local, national or international political conditions, riots or insurrections, (f) any action taken by, or at the written request of, the Company, (g) the announcement of this Agreement and consummation of the Transactions, including any termination of, reduction in or similar adverse impact (but in each case only to the extent attributable to the announcement of this Agreement or consummation of the Transactions) on SPAC’s relationships with any employees or Governmental Authorities (provided that this clause (g) shall not apply to any representations or warranty to the extent the purpose of such representation or warranty is to address the consequences resulting from this Agreement or the consummation of the Transaction) or (h) any change in the trading price or volume of the SPAC Units, SPAC Ordinary Shares or SPAC Warrants (provided that the underlying causes of such changes referred to in this clause (f) may be considered in determining whether there is a SPAC Material Adverse Effect except to the extent such cause is within the scope of any other exception within this definition); provided, however, that in the case of each of clauses (a), (b), (d) and (e), any such Event to the extent it disproportionately affects SPAC relative to other special purpose acquisition companies shall not be excluded from the determination of whether there has been, or would reasonably be expected to be, a SPAC Material Adverse Effect, but only to the extent of the incremental disproportionate effect on SPAC relative to such similarly situated participants. Notwithstanding the foregoing, with respect to SPAC, the number of SPAC Shareholders who exercise their SPAC Shareholder Redemption Right or the failure to obtain SPAC Shareholders’ Approval shall not be deemed to be a SPAC Material Adverse Effect;

  • Material Adverse Effect shall have the meaning assigned to such term in Section 3.1(b).

  • Material Adverse Change means any material adverse change in the business, condition (financial or otherwise), operations, performance, properties or prospects of the Borrower or the Borrower and its Subsidiaries taken as a whole.

  • Adverse impact means any deleterious effect on waters or wetlands, including their quality, quantity, surface area, species composition, aesthetics or usefulness for human or natural uses which are or may potentially be harmful or injurious to human health, welfare, safety or property, to biological productivity, diversity, or stability or which unreasonably interfere with the enjoyment of life or property, including outdoor recreation.