CNEL is a wholly-owned subsidiary and disregarded entity for federal income tax purposes and, accordingly, has been consolidated with all Tax Returns filed by Seller. CNEL has no employees. There are no Tax Liens on the Membership Interests or any assets of a CNEL, other than for current ...
“assets-over” partnership merger within the meaning of Treasury Regulations Section 1.708-1(c)(3)(i) pursuant to which the RIF V Fund contributes all of its assets and liabilities to the Operating Partnership in exchange for OP Units in a transaction qualifying under Section 721(a) of the...
If the refund of taxes and interest involves the withdrawal of funds from the national treasury, it shall be implemented in accordance with the specific implementation methods stipulated by laws, administrative regulations, and relevant rules and regulations on national treasury management. Section 2 Tax...