Template:M gen 2002 ISDA 6(b)(ii): Difference between revisions

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Created page with "=== Section {{isdaprov|6(b)(ii)}}: {{isdaprov|Transfer to Avoid Termination Event}} === Things start to go a bit wobbly. You sense that {{icds}} has been on the sauce or somet..."
 
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=== Section {{isdaprov|6(b)(ii)}}: {{isdaprov|Transfer to Avoid Termination Event}} ===
=== Section {{isdaprov|6(b)(ii)}}: {{isdaprov|Transfer to Avoid Termination Event}} ===
Things start to go a bit wobbly. You sense that {{icds}} has been on the sauce or something and has decided to codify the future. It gets worse before it gets better but here the permutations are about the parties Tax status: either the Tax ''law'' has changed for one or other party — a {{isdaprov|Tax Event}} — or a party has executed some fancy cross-border merger which has somehow changed its tax residence, status, or eligibility of favourable tax treatment: this is a {{isdaprov|Tax Event Upon Merger}}.
Things start to go a bit wobbly. You sense that {{icds}} has been on the sauce, or marching powder or something, and became attached to the idea of trying to codify the unknowable future. It gets worse before it gets better but here the permutations are about the parties ''tax'' status: either the Tax ''law'' has changed for one or other party — a {{isdaprov|Tax Event}} — or a party has executed some fancy cross-border merger which has somehow changed its tax residence, status, or eligibility of favourable tax treatment: this is a {{isdaprov|Tax Event Upon Merger}}. Here, in essence, you have a little window to sort yourself out, if you hadn’t done that ''before'' the merger (isn’t that what Tax advisors are for, by the way?).

Revision as of 17:47, 13 September 2022

Section 6(b)(ii): Transfer to Avoid Termination Event

Things start to go a bit wobbly. You sense that ISDA’s crack drafting squad™ has been on the sauce, or marching powder or something, and became attached to the idea of trying to codify the unknowable future. It gets worse before it gets better but here the permutations are about the parties tax status: either the Tax law has changed for one or other party — a Tax Event — or a party has executed some fancy cross-border merger which has somehow changed its tax residence, status, or eligibility of favourable tax treatment: this is a Tax Event Upon Merger. Here, in essence, you have a little window to sort yourself out, if you hadn’t done that before the merger (isn’t that what Tax advisors are for, by the way?).