Exchange Tax Covenant. (a) The parties intend that the Exchange will qualify as a tax-free transaction within the meaning of Section 351 of the Code in which the Company will not recognize gain or loss, and pursuant to which any gain recognized by Seller as a result of the Exchange will not exceed the amount of any cash received by a Seller in the Exchange (a "Reorganization").
Appears in 4 contracts
Samples: Agreement and Plan of Exchange (American Physician Partners Inc), Agreement and Plan of Exchange (American Physician Partners Inc), Agreement and Plan of Exchange (American Physician Partners Inc)
