Treasury Regulation Section 1.382 definition

Treasury Regulation Section 1.382 means the final and temporary income tax regulations promulgated under Section 382 of the Code and any successor temporary or final regulation or regulations. Each reference to any subsection of such regulations includes references to any successor to such subsection.
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Treasury Regulation Section 1.382 means the final and temporary income tax regulations promulgated under Section 382 of the Code and any
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Treasury Regulation Section 1.382 means the final and temporary
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Examples of Treasury Regulation Section 1.382 in a sentence

  • Notwithstanding the foregoing, nothing in this Section5.06 shall prevent a Person that is a member of a public group of the Corporation (as defined in Treasury Regulation Section 1.382- 2T(f)(13)) from transferring Corporation Securities to a new or existing public group of the Corporation.

  • Under this authority, Treasury and the IRS promulgated Treasury Regulation Section 1.382- 4(d) with respect to when options and similar instruments will be treated as stock for Section 382 purposes.

  • Although the potential types of instruments to which Treasury Regulation Section 1.382- 2T(f)(18)(iii) applies (i.e., “[a]ny ownership interest[s]” in a corporation that are not stock4 but offer a “potential significant participation in the growth of the corporation”) is broad and amorphous, this report addresses only debt instruments that were not treated as stock under Treasury Regulation Section 1.382-2T(f)(18)(iii) when originally issued (or, except as noted herein, deemed issued).

  • In addition, it was believed that transfers of interests in the PIK Facility were being made at significant discounts.On the basis of the facts presented in the ruling request, the IRS ruled that the PIK Facility should not be characterized as stock under Treasury Regulation Section 1.382- 2T(f)(18)(iii).

  • As discussed in Section B above, we believe Treasury Regulation Section 1.382- 2T(f)(18)(iii) should not treat distressed debt as stock if the debt instrument was not treated as stock upon issuance.

  • A Transfer also shall include the creation or grant of an option or of an interest that is similar to an option (within the meaning of Treasury Regulation Section 1.382 -2T(h)(4)(v)) to effect a Transfer.

Related to Treasury Regulation Section 1.382

  • Treasury Regulation means the United States Treasury regulations promulgated under the Code.

  • Treasury Regulations means the regulations promulgated under the Code.

  • U.S. Treasury Regulations means the Treasury regulations of the Code. Reference to a specific Treasury Regulation or Section of the Code shall include such Treasury Regulation or Section, any valid regulation promulgated under such Section, and any comparable provision of any future legislation or regulation amending, supplementing or superseding such Section or regulation.

  • Treasury means the United States Department of the Treasury.

  • Section 409A of the Code means the nonqualified deferred compensation rules under Section 409A of the Code and any applicable treasury regulations and other official guidance thereunder.

  • Reg means Internal Revenue Treasury Regulations.

  • Code Section 409A means Section 409A of the Code and the regulations and guidance promulgated thereunder.

  • the Code means the Pension Regulator’s Code of Practice No 14 governance and administration of public service pension schemes.

  • Federal Book-Entry Regulations means 31 C.F.R. Part 357 et seq. (Department of Treasury).

  • Section means a section of the Act.

  • IRC means the Internal Revenue Code of 1986, as amended.

  • Tax Regulations means the United States Treasury Regulations promulgated pursuant to sections 103 and 141 through 150 of the Code, or section 103 of the 1954 Code, as applicable.

  • Section 409A means Section 409A of the Code and the regulations and other guidance promulgated thereunder.

  • Federal internal revenue code means the federal internal

  • Section 382 means Section 382 of the Code, or any comparable successor provision.

  • Applicable Supervisory Regulations means the provisions of bank supervisory laws and any regulations and other rules thereunder applicable from time to time (including, but not limited to, the BRRD, the CRD, the CRR and the guidelines and recommendations of the European Banking Authority and/or the European Central Bank, the administrative practice of any competent authority, any applicable decision of a court and any applicable transitional provisions) relating to capital adequacy, solvency, other prudential requirements and/or resolution and applicable to the Issuer and/or the banking group to which the Issuer belongs from time to time.

  • Section 280G means Section 280G of the Code and the Treasury regulations promulgated thereunder or any similar or successor provision.

  • Plan Assets Regulation means 29 C.F.R. Section 2510.3-101, et seq., as modified by Section 3(42) of ERISA.

  • Short-Term Deferral Period means the period ending on the later of the 15th day of the third month following the end of the Executive’s tax year in which the separation from service occurs and the 15th day of the third month following the end of the Company’s tax year in which the separation from service occurs; and

  • Change in Control Event means any of the following:

  • Section 162(m) of the Code means the exception for performance-based compensation under Section 162(m) of the Code and any applicable treasury regulations thereunder.

  • Regulation CF means Regulation Crowdfunding promulgated under the Securities Act.

  • Line section means either that portion of an EDU's electric system connected to a customer bounded by automatic sectionalizing devices, the end of the distribution line, or a line segment identified as appropriate for study by a utility engineer.

  • Investor Money Regulations means the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) Investor Money Regulations 2015 for Fund Service Providers;

  • Federal Income Tax means any Tax imposed by Subtitle A of the Code, and any interest, penalties, additions to tax, or additional amounts in respect of the foregoing.

  • U.S. Internal Revenue Code means the United States Internal Revenue Code of 1986, as amended.