Treasury Regulations definition
Examples of Treasury Regulations in a sentence
For the avoidance of doubt, such agreement is intended to constitute a “written, binding agreement” to make the Section 336(e) Elections within the meaning of Treasury Regulations § 1.336-2(h)(1)(i).
Items of income, gain, loss, deduction and credit of CMJV shall be allocated among the Members in accordance with their Percentage Interests, subject to such adjustments as are required by Section 704 of the Internal Revenue Code of 1986, as amended (the “Code”), and the Treasury Regulations thereunder (including the requirements of Sections 704(b) and 704(c) of the Code), and CMJV shall maintain capital accounts for the Members in accordance with Treasury Regulations Section 1.704-1(b).
The Company and SpinCo shall take all actions necessary or appropriate to close the taxable year of SpinCo and each member of the SpinCo Group for all Tax purposes as of the close of the Distribution Date to the extent permissible or required under applicable Law, including, if permitted under applicable Tax Law, making the election under Treasury Regulations Section 1.245A-5(e)(3) with respect to each CFC Member and any corresponding or similar elections under state, local or non-U.S. law.
The Administrator (or the Owner Trustee at the request of the Administrator) will also establish and maintain, according to Section 1.704-1(b)(2)(iv) of the Treasury Regulations, a separate bookkeeping account for the Depositor and each other person treated as an equity owner of the Issuer for U.S. federal income tax purposes.
All terms used in this representation and warranty will have the same meanings as set forth in the related Treasury Regulations..