Treatment of Notes as Debt. It is intended that the Notes will be treated as indebtedness and not as equity for federal income tax purposes. The provisions of this Indenture shall be interpreted to further this intention.
Appears in 6 contracts
Sources: Indenture (CyrusOne Inc.), Indenture (International Flavors & Fragrances Inc), Indenture (Nutrition & Biosciences, Inc.)
Treatment of Notes as Debt. It is intended that the Notes will be treated as indebtedness and not as equity for federal income tax purposes. The provisions of this Indenture Note shall be interpreted to further this intention.
Appears in 1 contract
Sources: Note (Phoenix Energy One, LLC)
Treatment of Notes as Debt. It is intended that the Notes will be treated as indebtedness and not as equity for federal income tax purposes. The provisions of this Indenture shall be interpreted to further this intention.
Appears in 1 contract
Treatment of Notes as Debt. It is intended that the Notes will be treated as indebtedness (and not as equity or a “contingent payment debt instrument” governed by Section 1.1275-4 of Treasury Regulations) for federal income tax purposes and that the settlement of any Conversion Obligation of a Note will be treated as a tax-free transaction for federal income tax purposes. The provisions of this Indenture shall be interpreted to further this intention.
Appears in 1 contract
Treatment of Notes as Debt. It is intended that the Notes will be treated as indebtedness Indebtedness and not as equity for federal income tax purposes. The provisions of this Indenture shall be interpreted to further this intention.
Appears in 1 contract