Intended Tax Treatment. All parties to this Agreement covenant and agree to treat any Purchase and any drawing on a Letter of Credit under this Agreement as debt for all federal income tax purposes (the “Intended Tax Treatment”). All parties to this Agreement agree not to take any position on any tax return inconsistent with the Intended Tax Treatment.
Appears in 4 contracts
Samples: Receivables Purchase Agreement (Owens Corning), Receivables Purchase Agreement (Owens Corning), Receivables Purchase Agreement (Owens Corning)
Intended Tax Treatment. All parties to this Agreement covenant and agree to treat any Purchase and any drawing on a Letter of Credit under this Agreement as debt for all federal income tax purposes (the “Intended Tax Treatment”). All parties to this Agreement agree not to take any position on any tax return inconsistent with the Intended Tax Treatment.
Appears in 3 contracts
Samples: Receivables Purchase Agreement (Cloud Peak Energy Inc.), Receivables Purchase Agreement (Cloud Peak Energy Inc.), Receivables Purchase Agreement (Cloud Peak Energy Resources LLC)
Intended Tax Treatment. All parties to this Agreement covenant and agree to treat any Purchase and any drawing on a any Letter of Credit under this Agreement as debt of the Borrower to the Issuing Lender for all federal income tax Tax purposes (the “Intended Tax Treatment”). All parties to this Agreement agree not to take any position on any tax Tax return inconsistent with the Intended Tax Treatment.
Appears in 1 contract
Samples: Reimbursement Agreement (Hamilton Insurance Group, Ltd.)
Intended Tax Treatment. All parties to this Agreement covenant and agree to treat any Purchase and any drawing on a Letter of Credit under this Agreement as debt for all federal income tax purposes (the “Intended Tax Treatment”). All parties to this Agreement agree not to take any position on any tax return inconsistent with the Intended Tax Treatment.
Appears in 1 contract
