Tax Structure Memorandum means the tax structure memorandum prepared by PricewaterhouseCoopers LLP entitled “Project Triton - Structuring Strawman Paper” in connection with the Transactions.
Tax Structure Memorandum means the “Soho House Debt Restructuring: Accounting and Tax Considerations” report prepared by PricewaterhouseCoopers LLP delivered to the Original Notes Purchasers on or prior to the Closing Date.
Tax Structure Memorandum has the meaning given to that term in the Senior Facilities Agreement.
Examples of Tax Structure Memorandum in a sentence
The Company: Cobham Ultra SeniorCo S.à x.x., the entity identified as "Neptune SeniorCo" in the Tax Structure Memorandum.
US Co-Borrower: The entity identified as "US Co-Borrower" in the Tax Structure Memorandum.
Holdco: Cobham Ultra Limited, the entity identified as "Neptune UK HoldCo" in the Tax Structure Memorandum.
Cobham Ultra SunCo S.à x.x., the direct Holding Company of the Company, identified as "Neptune SUNco" in the Tax Structure Memorandum.
Bidco: Cobham Ultra Acquisitions Limited, the entity identified as "Cobham Neptune Bidco" in the Tax Structure Memorandum.
More Definitions of Tax Structure Memorandum
Tax Structure Memorandum means the tax structure memorandum titled “UK and Jersey corporation tax implications in respect of proposed Loan, Warrants and Options” prepared by Deloitte and delivered to the Agent pursuant to Clause 4.1 (Initial Conditions Precedent to the Utilisation).
Tax Structure Memorandum means the final report relating to the Restructuring produced by Xxxxxxx & Marsal Taxand UK LLP dated on or around the date of this Deed addressed to LTD;
Tax Structure Memorandum has the meaning assigned to such term in Section 4.01.
Tax Structure Memorandum means the KP Refinancing 2014/2015 Tax Technical Analysis of Contemplated Execution Steps, dated April 24, 2015, prepared by Ernst and Young.
Tax Structure Memorandum means the Project Xxxx – Tax Structure Memorandum dated July 24, 2014, prepared by Xxxxx and Xxxxx. NY\6497185.2 Exhibit 10.1 “Term Benchmark” when used in reference to any Loan or Borrowing, refers to whether such Loan, or the Loans comprising such Borrowing, are bearing interest at a rate determined by reference to Adjusted Term SOFR other than pursuant to clause (c) of the definition of “Base Rate”.
Tax Structure Memorandum means the tax structuring paper dated 24 June 2005 prepared by Deloitte & Touche LLP entitled “Project Toddler: Tax Structure Memorandum” relating to the Acquisition and the proposed changes in the Group structure occurring in anticipation of the Acquisition and following Closing and addressed to, and/or capable of being relied upon by, the Arrangers and the Finance Parties.
Tax Structure Memorandum means the structure paper entitled “Project Casablanca—tax steps paper” and dated April 17, 2011, describing the Parent and each of its Subsidiaries from time to time (including the Carbon Black Subsidiaries) and the Primary Acquisition and prepared by KPMG LLP UK in the agreed form together with any updates thereto or reissuances thereof that are provided in accordance with the terms of the Revolving Credit Facility to the extent any such updates or reissuances do not have a material adverse effect on the rights of holders of the Notes.