IRS Private Letter Ruling definition

IRS Private Letter Ruling means the private letter ruling issued by the IRS in response to the Application for Ruling.
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IRS Private Letter Ruling has the meaning set forth in the Tax Sharing Agreement.
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IRS Private Letter Ruling means the federal income tax rulings issued to Old Viacom on November 22, 2005 by the IRS in connection with the Separation Transactions.
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Examples of IRS Private Letter Ruling in a sentence

  • The Division may require an IRS Private Letter Ruling for projects that target a specific segment of the population.

  • General Public Use Requirements.The Division may require an IRS Private Letter Ruling for projects that target a specific segment of the population.

  • The payment of any investment advisory fees is guaranteed to be in accordance with Title 8, Section 830.107 of The Texas Government Code, as approved by IRS Private Letter Ruling dated August 30, 1990.

  • An IRS Private Letter Ruling issued 6/16/95, allowed a unit to be occupied by a security officer (a/k/a courtesy officer) if it was reasonably required by the development.

  • An IRS Private Letter Ruling may be required by the Division for projects that target a specific segment of the population to ensure compliance with the General Use requirement.

  • In case of a corporation, the same must be either under its seal or under the hand of an officer, attorney or other person duly authorised to sign the same.

  • The Board may seek such legal advice concerning the status of the Program and the Trust as it deems advisable, including (i) preparing and filing on behalf of the Trust an IRS Private Letter Ruling request, and (ii) preparing and filing a request for an SEC No-Action Letter.

  • The Contractor shall render assistance to the Board in the preparation of a request for an IRS Private Letter Ruling and/or SEC No-Action Letter.

  • For projects serving Frail Elderly and Alzheimer populations: Only 20/50 and 40/60 mixed-income projects are eligible for Tax Credits. Care services must be conducted on a 24-hour basis. The Division will require an IRS Private Letter Ruling or comparable legal opinion indicating that the project meets General Use requirements.

  • For instance, Kaheawa and Tax Foundation argue that at the federal level, the IRS has treated wind turbines as tangible personal property for energy credit and depreciation purposes (citing IRC §§ 48(a)(3), 168(e)(3)(B)(vi); IRS Private Letter Ruling 9007042 (1989) (credit allowed for wind turbines under IRC section saying that eligible property includes tangible personal property and other tangible property except a building and its structural components)).


More Definitions of IRS Private Letter Ruling

IRS Private Letter Ruling means the private letter ruling issued to VSI by the IRS, dated November 23, 2020.
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IRS Private Letter Ruling means a private letter ruling issued by the IRS in response to the Application for Ruling that provides that the Distribution will qualify under Section 355 and related provisions of the Code as a tax-free spin-off, and that no income, gain or loss will be recognized for U.S. federal income tax purposes by ICN, the stockholders or former stockholders of ICN, or any ICN Affiliate with respect to the Distribution.
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IRS Private Letter Ruling means the letter dated November 16, 2004 from Mxxxxxx X. Xxxxxx, Senior Technician Reviewer in the Office of Associate Chief Counsel of the IRS, to Bxxxxxx X. Xxxxxxxxxx, Vice President, Finance and CFO of Modine (the "Original Letter Ruling"), the original request for such letter ruling and all related documentation submitted to the IRS in connection with such request, and the supplemental letter ruling issued by the IRS and any documentation submitted in connection with the request for such supplemental letter ruling (the "Supplemental Ruling").
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IRS Private Letter Ruling means the supplemental private letter ruling from the United States Internal Revenue Service issued in connection with the Distribution on July 14, 2003, and, to the extent not superceded by such private letter ruling, the private letter ruling from the United States Internal Revenue Service issued in connection with the Distribution on September 30, 2002
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Related to IRS Private Letter Ruling

  • Private Letter Ruling shall have the meaning set forth in the Recitals.

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

  • Supplemental Ruling means (i) any ruling (other than the Ruling) issued by the IRS in connection with a Distribution, and (ii) any similar ruling issued by any other Taxing Authority addressing the application of a provision of the laws of another jurisdiction to a Distribution.

  • advance ruling means a decision provided by the Authority or the Appellate Authority to an applicant on matters or on questions specified in sub-section (2) of section 97 or sub-section (1) of section 100, in relation to the supply of goods or services or both being undertaken or proposed to be undertaken by the applicant;

  • Ruling Request means any letter filed by Parent with the IRS requesting a ruling regarding certain tax consequences of the Transactions (including all attachments, exhibits, and other materials submitted with such ruling request letter) and any amendment or supplement to such ruling request letter.

  • Alternative Acquisition Agreement shall have the meaning set forth in Section 6.5(c).

  • closing agreement as described in Section 7121 of the Code (or any corresponding or similar provision of state, local or foreign income Tax law) executed on or prior to the Closing Date; (iii) installment sale or open transaction disposition made on or prior to the Closing Date; or (iv) prepaid amount received on or prior to the Closing Date;

  • 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.

  • Post-Closing Agreement shall have the meaning set forth in Section 8.9.

  • Confirmation Letter means a letter issued by any applicable Rating Agency to the effect that neither (a) the resignation of Provident as Servicer under the Servicing Agreement and appointment of Litton as successor Servicer thereunder, nor (b) the amendments exxxxxxated by this Agreement, will adversely affect the then current ratings on the Certificates then being rated.

  • Company U.S. Counsel means Xxxxxx Xxxxxxx Xxxxxxxx & Xxxxxx, Professional Corporation.

  • Company Acquisition Agreement has the meaning set forth in Section 5.04(a).

  • 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.

  • Closing protection letter means an agreement by the division to indemnify a lender or owner or both for loss caused by a division closer’s theft of settlement funds or failure to comply with written closing instructions relating to title certificate coverage when agreed to by the division closer.

  • Implementation Letter means the letter of even date herewith from the Borrower to the Bank setting forth the Project monitoring indicators;

  • Tax Opinions means the opinions of Tax Advisors deliverable to OFC in connection with the Transactions.

  • Tax Certification Forms means any forms or other documentation as may be issued or required by a Tax Authority or by the Bank from time to time to confirm the tax status of the Customer or of a Connected Person.

  • Tax Compliance Agreement means the Federal Tax Certificate, Tax Compliance Agreement, Arbitrage Agreement, or other written certification or agreement of the Issuer setting out representations and covenants for satisfying the post-issuance tax compliance requirements for the Tax-Exempt Bonds.

  • Private Placement Agreement has the meaning set forth in Annex A hereto.

  • Post Closing Letter is that certain Post Closing Letter dated as of the Effective Date by and between Collateral Agent and Borrower.

  • Public-private partnership agreement means an agreement

  • Tax Regulatory Agreement means the Tax Regulatory Agreement dated as of the date hereof by and among the Company, the Issuer and the Trustee.

  • Exchange Administration Agreement means the exchange administration agreement dated as of the Closing Date between Freddie Mac and the Exchange Administrator.

  • Representation Letters means the statements of facts and representations, officer’s certificates, representation letters and any other materials (including, without limitation, a Ruling Request and any related supplemental submissions to the IRS or other Tax Authority) delivered by EQT, SpinCo or any of their respective Affiliates or representatives in connection with the rendering by Tax Advisors, and/or the issuance by the IRS or other Tax Authority, of the Tax Opinions/Rulings.

  • Tax Opinion means, with respect to any action, an Opinion of Counsel to the effect that, for federal income tax purposes, (i) following such action the Trust will not be deemed to be an association (or publicly traded partnership) taxable as a corporation, (ii) following such action the Trust will be disregarded as a separate entity from the Depositor, and (iii) such action will not affect the tax characterization as debt of Notes of any outstanding Class issued by the Trust for which an Opinion of Counsel has been provided that such Notes are debt.

  • Definitive Acquisition Agreement means any definitive written agreement entered into by the Company that is conditioned on the approval by the holders of not less than a majority of the outstanding shares of Common Stock at a meeting of the stockholders of the Company with respect to (i) a merger, consolidation, recapitalization, reorganization, share exchange, business combination or similar transaction involving the Company or (ii) the acquisition in any manner, directly or indirectly, of more than 50% of the consolidated total assets (including, without limitation, equity securities of its subsidiaries) of the Company and its Subsidiaries.