FEDERAL INCOME TAX CONSEQUENCES. For federal income tax purposes, it ------------------------------- is intended that the transfers described in Section 2.1, Section 2.2 and Section ----------- ----------- ------- 2.3 and the Merger qualify as a contribution to Xenon 2 qualifying under Section --- 351 of the Code.
Appears in 4 contracts
Samples: Agreement and Plan of Contribution, Investment and Merger (General Electric Co), Agreement and Plan of Contribution, Investment and Merger (Xoom Inc), Merger Agreement (Xoom Inc)
FEDERAL INCOME TAX CONSEQUENCES. For federal income tax purposes, it ------------------------------- is intended that the transfers described in Section 2.1, Section 2.2 and Section ----------- ----------- ------- 2.3 and the Merger qualify as a contribution to Xenon 2 qualifying under Section --- 351 of the Code.
Appears in 1 contract
Samples: Agreement and Plan of Contribution, Investment and Merger (General Electric Co)