U.S. Tax Ruling definition

U.S. Tax Ruling means the private letter ruling received from the IRS confirming the U.S. federal income tax consequences of certain aspects of the Pre-Arrangement Reorganization, the Arrangement and certain other transactions and includes any amendments and supplements thereto; and
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U.S. Tax Ruling means a private letter ruling from the U.S. Internal Revenue Service with respect to the U.S. federal income tax consequences of certain aspects of the Arrangement and related transactions.
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U.S. Tax Ruling means the private letter ruling issued to Novartis by the IRS in connection with the Transactions, as described in Exhibit A-1-D hereto.
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Examples of U.S. Tax Ruling in a sentence

  • In its sole and absolute discretion, Parent may elect to obtain a U.S. Tax Ruling.

  • The Company and Parent each agrees to consult with Parent or the Company, as the case may be, with respect to the request for the U.S. Tax Ruling.

  • Neither Parent nor the Company will take or fail to take (and, following the Merger, Parent will cause the Surviving Corporation to not take or fail to take) any action which action (or failure to act) would reasonably be expected to cause the Merger to fail to qualify as a reorganization within the meaning of Section 368(a) of the Code or would reasonably be expected to impede or preclude the IRS's issuance of the U.S. Tax Ruling prior to the Closing Date.


More Definitions of U.S. Tax Ruling

U.S. Tax Ruling has the meaning set forth in the Separation Agreement.”
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U.S. Tax Ruling has the meaning ascribed thereto on Schedule A-1.
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Related to U.S. Tax Ruling

  • Tax Ruling as used in this Agreement, shall mean a written ruling of a taxing authority relating to Taxes. "Closing Agreement", as used in this Agreement, shall mean a written and legally binding agreement with a taxing authority relating to Taxes.

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

  • IRS Ruling shall have the meaning set forth in the Recitals.

  • U.S. Tax Person means a Person that is a “United States person” as defined in Section 7701(a)(30) of the Code, generally including:

  • Income Tax Act means the Income Tax Act, 1962 (Act No. 58 of 1962);

  • U.S. Tax Certificate has the meaning assigned to such term in Section 2.17(f)(ii)(D)(2).

  • Income Tax Return means any return, declaration, report, claim for refund, or information return or statement relating to Income Taxes, including any schedule or attachment thereto, and including any amendment thereof.

  • Issuer Tax Opinion means with respect to any action, an Opinion of Counsel to the effect that, for federal income tax purposes and subject to customary assumptions and qualifications for opinions of this type, (a) such action will not adversely affect the tax characterization as debt of any Notes that were characterized as debt at the time of their issuance, and (b) following such action neither the Issuer nor the Titling Trust will be treated as an association (or publicly traded partnership) taxable as a corporation.

  • council tax benefit means council tax benefit under Part 7 of the SSCBA; “couple” has the meaning given by paragraph 4;

  • Debt-For-Tax Opinion means an Opinion of Counsel, of nationally recognized tax counsel, delivered to the Depositor and the Indenture Trustee stating that the Notes specified therein will be debt for United States federal income tax purposes.

  • Excise Tax Act means the Excise Tax Act (Canada);

  • Tax Opinions/Rulings means (i) any Ruling and (ii) any opinion of a Tax Advisor relating to the Transactions, including those issued on the Distribution Date or to allow a party to take actions otherwise prohibited under Section 4.03(a) of this Agreement.

  • Non-U.S. Tax Person A person other than a U.S. Tax Person.

  • Australian Tax Act means the Income Tax Assessment Act 1936 (Cth) (Australia) or the Income Tax Assessment Act 1997 (Cth) (Australia), as applicable.

  • Qualifying tax rate means the applicable tax rate for the taxable year for the which the taxpayer paid income tax to a municipal corporation with respect to any portion of the total amount of compensation the payment of which is deferred pursuant to a nonqualified deferred compensation plan. If different tax rates applied for different taxable years, then the “qualifying tax rate” is a weighted average of those different tax rates. The weighted average shall be based upon the tax paid to the municipal corporation each year with respect to the nonqualified deferred compensation plan.

  • U.S. Taxes means any present or future tax, assessment or other charge or levy imposed by or on behalf of the United States of America or any taxing authority thereof or therein.

  • Non-Income Tax Return means any Tax Return relating to any Tax other than an Income Tax.

  • Tax means any tax, levy, impost, duty or other charge or withholding of a similar nature (including any penalty or interest payable in connection with any failure to pay or any delay in paying any of the same).

  • Transaction Tax Deductions means any Tax deductions relating to (i) the Company Transaction Expenses, and (ii) repayment of the Indebtedness, including any unamortized deferred financing fees in connection with the Indebtedness.

  • Income Tax Returns means all Tax Returns relating to Income Taxes.

  • Tax Ordinance means the Israeli Income Tax Ordinance [New Version], 1961, as amended.

  • Intended Tax Treatment has the meaning specified in the Recitals hereto.

  • Foreign Income Tax means any Tax imposed by any foreign country or any possession of the United States, or by any political subdivision of any foreign country or United States possession, which is an income tax as defined in Treasury Regulation Section 1.901-2, and any interest, penalties, additions to tax, or additional amounts in respect of the foregoing.

  • Pre-Closing Tax Return has the meaning set forth in Section 7.1(a).

  • Tax roll means a permanent record of the taxes charged on property, as extended

  • Canadian Tax Act means the Income Tax Act (Canada), as amended.