Private Letter Ruling definition

Private Letter Ruling shall have the meaning set forth in the Recitals.
Private Letter Ruling means, in the event of a Distribution, (a) any private letter ruling issued by the IRS in connection with the Distribution or (b) any similar ruling issued by any other Tax Authority in connection with the Distribution.
Private Letter Ruling means the private letter ruling issued by the IRS to EFH Corp. on July 28, 2016.

Examples of Private Letter Ruling in a sentence

  • The Funds' multiple class program became effective on November 14, 1994 pursuant to: (i) Board approval of the program received on June 28, 1994; (ii) an SEC Exemptive Order dated June 21, 1994; and (iii) an IRS Private Letter Ruling dated May 10, 1994(2).

  • All Tax Returns filed pursuant to this Section 2 after the Distribution Date shall be prepared on a basis consistent with the rulings obtained from the Service in the Private Letter Ruling and the Tax Opinion (in the absence of a relevant change in law or circumstances).

  • The Funds also received an opinion letter from KPMG Peat Marwick LLP, dated September 7, 1994, that concludes that Class H shares, which were not included in the request for the Private Letter Ruling, are consistent with the holdings and requirements of the Ruling.

  • Notwithstanding any provision in this Section 6.03 to the contrary, the Committee shall have the discretion but not the obligation to fund this Plan through a trust of the type described in Internal Revenue Service Private Letter Ruling 8502023.

  • In its review of these reports the Directors should continue to keep in mind that the IRS issued a Private Letter Ruling relating to the Fund's multiple class structure at least partially on the basis of a representation by the Funds that the allocation of class expenses, excluding 12b-1 fees, will not cause a differential of 50 basis points or more among the per share distribution of a Fund's classes.


More Definitions of Private Letter Ruling

Private Letter Ruling means (a) any private letter ruling issued by the IRS in connection with any of the Spin-Off-Related Transactions or (b) any similar ruling issued by any other Tax Authority in connection with any of the Spin-Off-Related Transactions.
Private Letter Ruling means a private letter ruling issued by the IRS addressing the qualification of the Contribution, the Reorganized TCEH Conversion, and the Distribution as a “reorganization” within the meaning of Sections 368(a)(1)(G), 355 and 356 of the Internal Revenue Code and certain other matters.
Private Letter Ruling means the private letter ruling issued to UTC on December 13, 2019 in response to the IRS Ruling Request.
Private Letter Ruling shall have the meaning set forth in Section 3.01(a).
Private Letter Ruling shall have the meaning set forth in Section 7.05.
Private Letter Ruling shall have the meaning set forth in the Separation Agreement.
Private Letter Ruling means the private letter ruling issued by the Service to FIS that addresses, inter alia, the tax consequences of the Contribution, Distribution, and Debt Exchange.