The grantor maintains the right to terminate
this provision, at which point the trust would no longer be defective.
As a result of BMCA's offer, ElkCorp sent notice to Carlyle of ElkCorp's intention to terminate
the Carlyle agreement.
The IRS found that either event would terminate
the S election, but deemed both to be inadvertent.
In light of MDM's non-delivery of the Performance Security, the Company has given 14 days notice to MDM that the Company has the right under the LSTK, but not the obligation, at the expiry of the notice period, to terminate
Effect: The election out will be effective for T's transfers to B in 2006 and for all future transfers to be made by T to B, unless and until T terminates
the election out.
The 13-mile railroad, which originates at Alcoa's plant, terminates
in Lolita, Texas.
2004-85 addressed the issue of when a QSub election terminates
in a merger.
King's plan terminates
on the earlier of September 30, 2005 or when all of the shares subject to the plan are sold.
If the QSub election subsequently terminates
(whether by choice or by a change in either the parent's or the subsidiary's eligibility for S or QSub status), Sec.
12-Year Relationship With Cendant Mobility Network
Several situations arose this year that addressed when an S election terminates
In the event BRE fails to terminate
the agreement on or before January 31, 2002 pursuant to the termination right mentioned above, unless BRE elects for the deposit to become non-refundable, ILM II will be permitted to enter into a back-up agreement with a third party for the sale of the facilities, which third party agreement will become effective in the event BRE terminates