Our society has been changing its collective
opinion of counseling — we are more accepting than ever of the benefit that therapy can provide us.
As discussed above, notwithstanding receipt by HP Co. of a private letter ruling from the IRS and / or
opinions of counsel and other external tax advisors, the IRS could assert that the distribution does not qualify for tax - free treatment for U.S. federal income tax purposes.
Accordingly, notwithstanding receipt of the IRS private letter ruling and / or
opinions of counsel or other external tax advisors, the IRS could determine that the distribution and certain related transactions should be treated as taxable transactions for U.S. federal income tax purposes if it determines that any of the facts, assumptions, representations, statements or undertakings that were included in the request for the IRS private letter ruling or on which any opinion was based are false or have been violated.
An opinion of counsel, however, is not binding on the IRS or on the courts, and does not preclude the IRS from taking a contrary position.
Oct. 19, 2011: Mei writes Garry that SRB was applying for financing through NDH Capital Corp, again for improvements at Woodlands: «NDH Capital Corp. is requiring the town to secure
an opinion of counsel letter from independent outside counsel stating the town is authorized to make the necessary amendments,» to Singh's concession agreements.
In the event that a claim for indemnification against such liabilities (other than the payment by the registrant of expenses incurred or paid by a trustee, officer or controlling person of the registrant in the successful defense of any action, suit or proceeding) is asserted by such trustee, officer or controlling person in connection with the securities being registered, the registrant will, unless in
the opinion of its counsel the matter has been settled by controlling precedent, submit to a court of appropriate jurisdiction the question whether such indemnification by it is against public policy as expressed in such Act and will be governed by the final adjudication of such issue.
In the event that a claim for indemnification against such liabilities (other than the payment by Registrant of expenses incurred or paid by a trustee, officer or controlling person of Registrant in the successful defense of any action, suit or proceeding) is asserted by such trustee, officer or controlling person in connection with the securities being registered, Registrant will, unless in
the opinion of its counsel the matter has been settled by controlling precedent, submit to a court of appropriate jurisdiction the question whether such indemnification by it is against public policy as expressed in the 1933 Act and will be governed by the final adjudication of such issue.
With more than 50 registered patent attorneys with diverse technical backgrounds, Sheppard Mullin offers a complete patent practice, including patent prosecution, licensing and related transactional matters, as well as providing
opinions of counsel, strategic audits and due diligence in connection with corporate transactions.
Opinions of counsel are key and they must address non-infringement.
As a trusted advisor to our clients, we render
opinions of counsel to guide and inform your management team regarding patent rights.
The document involved was clearly attorney - client privileged on its face as it contained
an opinion of counsel, but the manner in which came into possession of counsel raised a strong argument of waiver.
Not exact matches
Thursday's sanctions target Russians indicted last month as part
of the special
counsel Robert Mueller's investigation into Russia's election meddling on charges
of conspiracy to interfere in the election by waging a social - media influence operation to sow discord and sway public
opinion in the US in favor
of Trump.
ETE said it provided written notice terminating the deal due to failure
of conditions under the merger agreement, including company
counsel Latham's inability to deliver the required tax
opinion.
Evercore is acting as financial advisor to a committee
of independent directors
of T - Mobile and rendered a fairness
opinion, and Latham & Watkins is providing legal
counsel to the committee
of independent directors.
In my personal
opinion, the emphasis upon taking out insurance against downside risks lies in conflict with the shift to data dependency given long and variable lags
of monetary policy impacts on the broader economy which could have
counselled front - loading insurance cuts rather than scattering them (if delivering any more at all) in which case precious little insurance has been taken out.
Any
opinions of outside
counsel or other external tax advisors and any IRS private letter ruling will be based, among other things, on various facts and assumptions, as well as certain representations, statements and undertakings
of HP Co. and Hewlett Packard Enterprise (including those relating to the past and future conduct
of HP Co. and Hewlett Packard Enterprise).
Any
opinions of outside
counsel or any other external tax advisor and any IRS private letter ruling will be based, among other things, on various facts and assumptions, as well as certain representations, statements and undertakings
of HP Co. and Hewlett Packard Enterprise (including those relating to the past and future conduct
of HP Co. and Hewlett Packard Enterprise).
Delivering a legal
opinion requires a certain level
of work by company
counsel, which increases legal fees.
In my
opinion, Carhart's research
counsels skepticism toward those studies that claim you could have beaten the market over time by investing in the hottest funds
of the previous year.
Marriott International has received a private letter ruling from the Internal Revenue Service and an
opinion of tax
counsel confirming that the distribution
of shares
of Marriott Vacations Worldwide common stock will qualify as a tax - free distribution to Marriott International shareholders.
As a patent attorney, his practice focuses on patent preparation and prosecution in a wide variety
of mechanical, electrical and computer arts, as well as
opinions and IP portfolio
counseling, for clients ranging from Fortune 500 companies to start - ups.
Justice Harry Blackmun, who had been
counsel for the Mayo Clinic, wrote much
of the majority
opinion in Roe at the Mayo Clinic library.
While the case was decided 5 — 4, the
opinions that accompanied the court's decision also signal that seven
of the nine justices agree that businesses can make religious liberty claims in court — an important ruling, said Joshua Hawley, senior
counsel for The Becket Fund for Religious Liberty.
Once a brand name is selected and before it is actually adopted, you would be wise to seek the advice
of IP
counsel for a clearance
opinion to minimize the risk
of pursuing a course that may infringe another's rights.
It turns out that I'm not alone in my
opinion of marriage
counseling.
«The company relied on the police, the Press Complaints Commission... and the legal
opinion of outside
counsel brought in...» He's saying that News International couldn't have known
of «any additional illegality» because the police had told them that was the case.
Senate Republicans on Monday leaned heavily on the legal
opinion of the conference's top
counsel who released a 4 - page legal
opinion on Saturday night concluding the arrangement didn't violate the law.
David Lewis,
counsel to Senate Majority Leader John Flanagan, released an
opinion declaring the payments as «proper under the authority
of the New York State Constitution.»
David Lewis,
counsel to Senate Majority Leader John Flanagan, issued an
opinion over the weekend that defended the legality
of the practice.
A legal
opinion from Senate GOP
counsel David Lewis released Saturday night said the committee chairman title in the paperwork submitted with the controller's office was used as a type
of accounting code rather than to identify the title
of specific senators receiving the stipends.
The
opinions were written by the department's Office
of Legal
Counsel amid investigations into President Richard M. Nixon and President Bill Clinton.
In the new
opinion, David Barron, the acting head
of the Office
of Legal
Counsel, wrote that the statute — a restriction Congress imposed in the State Department's annual budget bill — «unconstitutionally infringes on the president's authority to conduct the nation's diplomacy, and the State Department may disregard it.»
With Kenya's presidential election drawing near, campaigns here are for the first time making widespread use
of opinion polls, text messaging, teleprompters, spin doctors, $ 15,000 - a-plate fundraisers and even high - powered foreign political consultants such as Dick Morris, a former adviser to Bill Clinton, who swooped in for a few days to
counsel opposition candidate Raila Odinga.
In one
opinion, Barry Ginsberg, executive director and general
counsel of the New York State Commission on Public Integrity, said state law allows a local municipality to accept the state disclosure form in place
of the local form.
Brooke included a «
counsel's
opinion'that the Water Act
of 1989, which established the NRA, requires the authority to consider the option
of retreat and the environmental benefits that might follow, whenever it assesses the cost
of coastal defence projects.
Randall G. Bennett is the Deputy Executive Director and General
Counsel of the Tennessee School Boards Association where he provides general legal
opinions to local boards
of education, superintendents and TSBA staff on school governanace issues, organizes and presents at seminars and training events, prepares and files amicus briefs in appellate cases affecting public schools, monitors current litigation and changes in state and federal law, and supervises the Association's Policy Department, A former school board member and police officer, Mr. Bennett obtained his law degree from Nashville School
of Law.
At the request
of the Board, the Secretary asked the Department's Office
of Chief
Counsel to render an
opinion on the issue.
The California Senate Legislative
Counsel issued last week a sweeping
opinion, concluding a controversy as to whether a school district — Los Angeles Unified, in this case — can proclaim itself exempt from California's historic Parent Trigger law, which enables parents
of kids in chronically underperforming schools to transform it if a majority
of parents -LSB-...]
In addition to the expert
opinion, legal arguments pertaining to mootness and ripeness, as well as a strong defense
of CCJEF's legitimate standing in the case, the reply brief was offered by
counsel for the plaintiffs, Debevoise & Plimpton LLP (New York), with assistance from the Yale Law School Education Adequacy Clinic, both
of which serve pro bono in this action.
From time to time, the Office
of the General
Counsel generates documents, such as legal
opinions and interpretations, that may be
of interest to the public and helpful in understanding law and regulations pertinent to transportation.
Opinion of borrower's
counsel (addressing legal authority
of Borrower, execution
of documents, etc.) and
of bond
counsel (addressing legality and validity
of security interests and validity, priority and perfection
of lien, if applicable, and due authorization, legality, and binding nature
of the credit instrument)
A poll
of both traditional lenders (such as banks and national mortgage companies), and non-traditional lenders (such as sub-prime lenders, non-conforming mortgage companies, and finance companies) yielded a fairly unanimous
opinion: being in a debt
counselling program or consumer credit
counseling program was just as damaging to a person's credit as filing a bankruptcy.
Legal
opinion: A written
opinion by a bond
counsel stating whether or not a bond issue conforms with all the laws
of the issuer, and the state and federal governments.
The Office
of the Superintendent
of Bankruptcy (OSB) is currently conducting a review
of the credit
counselling requirement so we think it is appropriate that we express our
opinion on the matter.
First and foremost, we are
of the
opinion that credit
counselling has the ability to provide a real benefit to the individuals that receive it.
The National Foundation for Credit
Counseling (NFCC) recently surveyed peoples»
opinions of their mother's personal finance skills.
Okay (bearing in mind that the
opinion of an IRS
counsel does NOT make it the law), but...
In any event, in a previous posting, Anthony provided a link to the written
Opinion of learned
Counsel to the effect that I am a member
of the Lords, and that I am fully entitled to say so.
replete with such language: it disdains the district court's «abrupt handling»
of Appellant's first case; sarcastically refers to Appellant's previous
counsel's «new - found appreciation for defendant's mental abilities;» criticizes the district court's «oblique language» on an issue unrelated to this appeal; states that the district court
opinion in Jones «revealed a crabby and complaining reaction to Project Exile;» insinuates that the district court's concerns «require -LSB--RSB- a belief in the absurd that is similar in kind to embracing paranormal conspiracy theories;» and accuses Appellant
of being a «charlatan» and «exploit [ing] his identity as an African - American.»
The page includes a plain - English summary
of the case, the questions presented, and links to blog commentary, the lower - court
opinions, the oral argument transcript, all briefs, the decision when issued,
counsel for each party, and outside resources.