Examples of Weatherford Parent in a sentence
On the Distribution Record Date, the Claims Register (and the Debtors’ books and records with respect to the Holders of Equity Interests in Weatherford Parent) will be closed.
For the avoidance of doubt, Weatherford Bermuda and Weatherford Delaware may make payments on behalf of Weatherford Parent that would otherwise be considered prepetition claims of Weatherford Parent in the Irish Scheme of Arrangement so long as such payments are in the ordinary course of business and otherwise in accordance with the terms of this Plan and the DIP Orders.
Because Weatherford Parent is an Irish incorporated entity, it would generally be classified as a foreign corporation under these rules.
Weatherford Parent is an Irish public limited company that is a Swiss tax resident.
The examiner, when appointed, will be an independent officer of the High Court of Ireland and will be free to adopt or decline to adopt the terms of the proposals for a scheme of arrangement accompanying the petition to have an examiner appointed to Weatherford Parent.
The United States Internal Revenue Service (the “IRS”) may, however, assert that Weatherford Parent should be treated as a U.S. corporation for U.S. federal income tax purposes pursuant to IRC Section 7874.
Following the Effective Date, the Reorganized Debtors intend to continue to operate under Weatherford Parent, which is expected to be an Irish tax resident following the Irish Migration (as defined below).
Any interest income received by Weatherford Parent is subject to tax at 25%.
In addition, these discussions do not address tax consequences that may be relevant to Holders of Claims other than Prepetition Notes Claims or of Equity Interests other than Existing Common Stock.The following discussions assume that the Internal Reorganizations will occur prior to or on the Effective Date and in accordance with the Description of Reorganization Steps and that Weatherford Parent will continue as the parent of the group following the Effective Date.
Weatherford Parent believes that the examiner will adopt and put the proposals before meetings of Weatherford Parent’s shareholders and creditors and subsequently seek their approval by the High Court of Ireland, because the proposals will, insofar as Weatherford Parent is concerned, mirror the Plan and the Plan represents the best solution achievable for the Debtors, their creditors and shareholders.