Common use of Federal Income Taxation Clause in Contracts

Federal Income Taxation. Zions Bancorp and the Company shall have received a written opinion of Rothgerber, Appel, Powers & Xxxxxxx LLP, or of McGladrey & Xxxxxx, LLP, or of another firm mutually agreeable to Zions Bancorp and the Company, applying existing law, that the reorganization contemplated by this Agreement shall qualify as one or more reorganizations under section 368(a)(1) of the Code and the regulations and rulings promulgated thereunder.

Federal Income Taxation. Zions Bancorp and the Company shall have received a written opinion of Rothgerber, Appel, Powers Xxxxx & Xxxxxxx Xxxxxxxxx LLP, or of McGladrey Duane, Morris & Xxxxxx, Heckscher LLP, or of another firm mutually agreeable to Zions Bancorp and the Company, applying existing law, that the reorganization Holding Company Merger and Bank Merger contemplated by this Agreement shall each qualify as one or more reorganizations under section 368(a)(1) of the Code and the regulations and rulings promulgated thereunder.

Federal Income Taxation. Zions Bancorp and the Company shall have received a written opinion of RothgerberDuane, Appel, Powers Morris & Xxxxxxx LLP, or of McGladrey & Xxxxxx, Heckscher LLP, or of another firm mutually agreeable to Zions Bancorp and the Company, applying existing law, that the reorganization contemplated by this Agreement shall qualify as one or more reorganizations under section 368(a)(1) of the Code and the regulations and rulings promulgated thereunder.

Federal Income Taxation. Zions Bancorp and the Company shall have received a written opinion of RothgerberDuane, Appel, Powers Morris & Xxxxxxx Heckscher LLP, or of McGladrey & Xxxxxx, LLP, or of another firm mutually agreeable to Zions Bancorp and the Company, applying existing law, that the reorganization contemplated by this Agreement shall qualify as one or more reorganizations under section 368(a)(1) of the Code and the regulations and rulings promulgated thereunder.