FCC Web Documents citing 1.1502
- http://www.fcc.gov/transaction/att-comcast/comcast_separationagreement.pdf
- patent applications, trade secrets and other technology to the extent it is allocated in the Intellectual Property Agreement, except for transfers made pursuant to the Patent Assignment. (h) Anything in this Agreement to the contrary notwithstanding, if either AT&T or Comcast reasonably believes that the amount of income that would otherwise be required to be recognized under Treasury Regulations Section 1.1502-13 or 1.1502-19 by reason of the Distribution may be reduced or eliminated as a result of one or more restructuring transactions consummated prior to the Distribution, then the parties shall negotiate in good faith to reach agreement regarding such restructuring transaction. Notwithstanding anything in the preceding sentence, AT&T shall be permitted to effect, at its own expense, any restructuring transaction
- http://www.fcc.gov/transaction/nbc-telemundo/exhibit6.pdf
- (and not as an entity taxable as a corporation); (xiii) except for the group of corporations that includes only the Company and the Subsidiaries, neither the Company nor any Subsidiary has ever been a member of any consolidated, combined or affiliated group of corporations for any Tax purposes or subject to liability for any other corporation's Taxes under Treasury Regulations 1.1502-6 or any analogous or similar state, local or foreign law or regulation; (xiv) none of the Company Stockholders nor the S Sub is a foreign person within the meaning of Section 1445 of the Code; (xv) Section 3.7(a)(xv) of the Company Disclosure Schedule sets forth, to the knowledge of the Company, (A) each ownership change (within the meaning of Section