Federal Income Tax Reporting. At all times when there is only one Member, all items of income, gain, loss, deduction and credit of the Company shall be reported on the Member’s federal income tax return.
Federal Income Tax Reporting. (a) Subject to definitive guidance from the IRS or a court of competent jurisdiction to the contrary (including receipt by the Liquidating Trustee of a private letter ruling if the Liquidating Trustee so requests one, or the receipt of an adverse determination by the IRS upon audit if not contested by the Liquidating Trustee), the Liquidating Trustee shall file returns for the Liquidating Trust as a grantor trust pursuant to Treasury Regulation Section 1.671-4(a) and in accordance with this Article 5, which returns shall reflect all of the earnings of the Liquidating Trust, including those retained for purposes of a reserve for Disputed Claims. The Liquidating Trustee shall also annually send to each Liquidating Trust Beneficiary a separate statement setting forth such Liquidating Trust Beneficiary’s share of items of income, gain, loss, deduction, or credit and will instruct all such holders to report such items on their federal income tax returns.
Federal Income Tax Reporting. The Liquidating Trustee will file annually on a timely basis the appropriate tax returns for the Trust and which treat the Trust as a grantor trust pursuant to U.S Treasury Regulation Section 301.7701-4(d), and will provide each Beneficiary with the information needed to file his or her federal income tax return. The Liquidating Trustee will file any other tax forms or reports that are required with respect to the Trust or its Beneficiaries.
Federal Income Tax Reporting. GBT and the Shareholder agree to report the Merger as a "reorganization," within the meaning of Section 368(a) of the Code.
Federal Income Tax Reporting. Notwithstanding anything to the contrary contained herein, each party hereto hereby acknowledges and agrees that for United States federal, state and local income tax purposes, the aggregate “issue price” of the Securities under Section 1273(b) of the Code shall equal the principal amount of any such Securities on the date of issuance. Each party hereto agrees to use the foregoing issue price for all income tax, financial accounting and regulatory purposes with respect to this transaction. Each party hereto further acknowledges and agrees that the Obligations shall be treated as debt for all tax and accounting purposes and no party shall take any position inconsistent therewith.
Federal Income Tax Reporting. The Partners hereby agree that the Partners and the Partnership will treat the transactions consummated pursuant to Section 6.1.1, 6.1.2, 6.1.3 and 6.1.4 hereof in the following manner for federal income tax purposes:
Federal Income Tax Reporting. MergerCo and the Shareholders agree to report the Merger as a "reorganization," within the meaning of Section 368(a) of the Code, but the Shareholders shall not be liable for any adverse consequences suffered by XOOM or the Company if the Merger fails to qualify as a reorganization.
Federal Income Tax Reporting. Notwithstanding anything to the contrary contained herein, each party hereto hereby acknowledges and agrees that for United States federal, state and local income tax purposes, the aggregate “issue price” of the Notes under Section 1273(b) of the Code shall equal $25,000,000. Each party hereto agrees to use the foregoing issue price for all income tax, financial accounting and regulatory purposes with respect to this transaction. Each party hereto further acknowledges and agrees that the Obligations shall be treated as debt for all tax and accounting purposes and no party shall take any position inconsistent therewith.
Federal Income Tax Reporting. For federal income tax purposes, the Trustee shall file such returns and statements as in its judgment are required to comply with applicable provisions of the Code and regulations and to permit each Certificate Holder correctly to report his share of the income and deductions of the Trust. The Trustee intends to treat all income and deductions of the Trust for each month as having been realized on the Monthly Record Date for such month unless otherwise advised by counsel or the Internal Revenue Service.
Federal Income Tax Reporting. The Partners hereby acknowledge and agree that, pursuant to Section 707(a)(2)(B) of the Code, the transfer of the Assets to the Partnership by the Company shall, for federal income tax purposes, be treated as follows: (i) a sale by the Company to RVC of an undivided interest in the Assets for the Cash Contribution, followed by the contribution of such undivided interest by RVC to the Partnership, and (ii) a contribution by the Company to the Partnership of its remaining undivided interest in the Assets (such transaction being hereinafter referred to as the "Part Sale/Part Contribution Transaction"). For purposes of this Section 6.1.6, unless a different percentage is expressly stated, the undivided interest in Assets deemed purchased by RVC shall be that percentage determined by multiplying (i) the ratio of the Cash Contribution to the Agreed Value of the Assets, and (ii) 100 percent. In connection with the foregoing, the Partners hereby acknowledge and agree that, as of the date of this Agreement, the United States Treasury Department has not yet promulgated proposed, temporary or final regulations ("Treasury Regulations") interpreting Section 707(a)(2)(B) of the Code and whether the distribution of the Loan Proceeds to the Company may, in whole or in part, be regarded as a nontaxable distribution to the Company. Accordingly, the Partners hereby agree that if and to the extent that Treasury Regulations are promulgated which permit the Company to take the position that its receipt of the Loan Proceeds properly may be treated as a nontaxable distribution to the Company, then the Part Sale/Part Contribution Transaction shall, for federal income tax purposes, be reported by the Partnership and the Partners as (i) a sale by the Company to RVC of an undivided interest in the Assets for the Cash Contribution, (ii) a contribution by the Company and RVC of their respective undivided interests in the Assets to the Partnership, and (iii) a financing transaction pursuant to which the Partnership borrowed the Loan Proceeds and distributed such Loan Proceeds to the Company pursuant to Section 731 of the Code. The Partners further recognize and agree that, if Treasury Regulations are not issued under Section 707(a)(2)(B) of the Code prior to the filing of the Partnership's initial federal income tax return, the Part Sale/Part Contribution Transaction shall be reported as (i) a sale by the Company to the Partnership of an undivided 50% interest in the Asset for the Cash ...
