Federal Income Tax Treatment of Merger. The merger is intended to qualify as and, subject to the requirements of Section 368(a)(2)(E) of the Internal Revenue Code of 1986, as amended (the "Code"), shall be characterized as a tax-free reverse subsidiary merger transaction described in Section 368(a)(2)(E) of the Code.
Appears in 2 contracts
Samples: Plan and Agreement of Merger (Synagro Technologies Inc), Plan and Agreement of Merger (Synagro Technologies Inc)
Federal Income Tax Treatment of Merger. The merger is intended to qualify as and, subject to the requirements of Section 368(a)(2)(E368(a)(1)(A) of the Internal Revenue Code of 1986, as amended (the "Code"), shall be characterized as a tax-free reverse subsidiary merger transaction described in Section 368(a)(2)(E368(a)(1)(A) of the Code.
Appears in 2 contracts
Samples: Plan and Agreement (Iteq Inc), Plan and Agreement of Merger (Astrotech International Corp /New)
Federal Income Tax Treatment of Merger. The merger is intended to qualify as and, subject to the requirements of Section ss. 368(a)(2)(E) of the Internal Revenue Code of 1986, as amended (the "Code"), shall be characterized as a tax-free reverse subsidiary merger transaction described in Section ss. 368(a)(2)(E) of the Code.
Appears in 1 contract
Samples: Plan and Agreement of Merger (Synagro Technologies Inc)
Federal Income Tax Treatment of Merger. The merger is intended to qualify as and, subject to the requirements of Section 368(a)(2)(E368(a)(1)(A) of the Internal Revenue Code of 1986, as amended (the "Code"), shall be characterized as a tax-free reverse subsidiary merger transaction described "reorganization" as defined in Section 368(a)(2)(E368(a)(1)(A) of the Code.
Appears in 1 contract
Samples: Plan and Agreement of Merger (Esenjay Exploration Inc)
Federal Income Tax Treatment of Merger. The merger is intended to qualify as and, subject to the requirements of Section 368(a)(2)(E368 (a) (1) (A) of the Internal Revenue Code of 1986, as amended (the "Code"), shall be characterized as a tax-free reverse subsidiary merger transaction described "reorganization" as defined in Section 368(a)(2)(E368 (a) (1) (A) of the Code.
Appears in 1 contract
Samples: Plan and Agreement of Merger (Ponder Industries Inc)
Federal Income Tax Treatment of Merger. The merger is intended to qualify as and, subject to the requirements of Section 368(a)(2)(ESections 368(a)(1)(A) and 368(a)(2)(D) of the Internal Revenue Code of 1986, as amended (the "Code"), shall be characterized as a tax-free reverse subsidiary merger transaction reorganization described in Section 368(a)(2)(ESections 368(a)(1)(A) and 368(a)(2)(D) of the Code.
Appears in 1 contract