Federal Income Tax Treatment. The parties have determined that this Agreement shall be treated as a contingent payment debt instrument for U.S. federal income tax purposes as of the Closing Date. Except as otherwise required by law, the parties shall report all payments under this Agreement in a manner consistent with the treatment of this Agreement as a debt instrument on the parties’ respective federal income tax returns.
Appears in 3 contracts
Samples: Investment Agreement, Investment Agreement, Investment Agreement
Federal Income Tax Treatment. The parties have determined that this Agreement shall be treated as a contingent payment debt instrument for U.S. federal income tax purposes as of the Closing DateDate and it may have original issue discount. Except as otherwise required by law, the parties shall report all payments under this Agreement in a manner consistent with the treatment of this Agreement as a debt instrument on the parties’ respective federal income tax returns.
Appears in 2 contracts
Federal Income Tax Treatment. The parties have determined that this Agreement shall be treated as a contingent payment debt instrument for U.S. federal income tax purposes as of the Closing Date. Except as otherwise required by law, the parties shall report all payments under this Agreement in a manner consistent with the treatment of this Agreement as a debt instrument on the parties’ respective federal income tax returns.
Appears in 1 contract
Samples: Investment Agreement