Examples of Term Loan Facility Claim in a sentence
Any Secured Claim other than (a) a DIP Facility Claim, (b) an ABL Claim, (c) a Term Loan Facility Claim, or (d) a Secured Tax Claim.
To the extent that the IRS disagrees with such treatment, the U.S. federal income tax consequences to a Holder that exchanges its Allowed Term Loan Facility Claim for (i) its pro rata share of 100% of the New Holdco Common Stock and (ii) its pro rata share of 100% of the Subordinated Notes will differ materially from the consequences described below.
To relaunch the domestic economic wheel, it will have to accelerate crisis recovery and put the whole country on the track towards development.
To the extent that a Holder of an Allowed Term Loan Facility Claim does not recognize accrued market discount upon the Section 721 Contribution, then such Holder likely will be required to recognize such accrued market discount upon the New Holdco Contribution if the New Holdco Contribution is treated as a Section 351 Exchange with respect to such Holder.
Subject to certain exceptions, such gain or loss generally should be capital in nature and should be long-term capital gain or loss to the extent the Holder has a holding period for its Equity Interest (which generally should include such Holder’s holding period for the debt obligation underlying the surrendered Allowed Term Loan Facility Claim) of more than one year.
A Holder of an Allowed Term Loan Facility Claim that is subject to this treatment should recognize gain or loss equal to the difference between (i) the fair market value of the shares of New Holdco Common Stock and (ii) the Holder's adjusted tax basis in its New Opco Common Units.
A Holder’s holding period for its pro rata share of the Subordinated Notes received in exchange for an Allowed Term Loan Facility Claim should begin on the day following the Effective Date.
Holders that exchange an Allowed Term Loan Facility Claim for a pro rata share of the Subordinated Notes are urged to consult their own tax advisors regarding the application of these rules to the Subordinated Notes.
A Holder’s holding period for its New Holdco Common Stock should include the holding period for the New Opco Common Units (which generally should include such Holder’s holding period for the debt obligation underlying the surrendered Allowed Term Loan Facility Claim).
A Holder’s holding period for the New Opco Common units should include such Holder’s holding period for debt obligation underlying the surrendered Allowed Term Loan Facility Claim.