Common use of For U Clause in Contracts

For U. S. federal income tax purposes, the Parties (as defined below) intend for the Merger (as defined below) provided for herein to qualify as a “reorganization” under the provisions of Section 368(a) of the Code (as defined below), and this Agreement is intended to be and is adopted as a “plan of reorganization” for purposes of Sections 354, 361, and 368 of the Code and within the meaning of Treasury Regulation Section 1.368-2(g).

For U. S. federal income tax purposes, the Parties (as defined below) parties to this Agreement intend for that the Merger (as defined below) provided for herein to will qualify as a “reorganization” under within the provisions meaning of Section 368(a) of the Internal Revenue Code of 1986, as amended (as defined belowthe “Code”), and this Agreement is intended to be and is adopted as will constitute a “plan of reorganization” within the meaning of United States Treasury Regulations Sections 1.368-2(g) and 1.368-3(a) for purposes of Sections 354, 361, 361 and 368 of the Code and within the meaning of Treasury Regulation Section 1.368-2(g)Code.

For U. S. federal income tax Tax purposes (and, where applicable, state and local income Tax purposes), the Parties intend that (as defined belowi) intend for the Parent Merger (as defined below) provided for herein to qualify as a “reorganization” under within the provisions meaning of Section 368(a) of the Code Code, (ii) the Mergers, taken together, qualify as defined below)an exchange within the meaning of Section 351 of the Code, and (iii) this Agreement is intended to be be, and is adopted hereby adopted, as a “plan of reorganization” for purposes within the meaning of Sections 354, 361, and 368 of the Code and within the meaning of Treasury Regulation Section 1.368-2(g)Regulations promulgated thereunder.

For U. S. federal income tax Tax purposes, the Parties it is intended that (as defined belowi) intend for the Merger (as defined below) provided for herein to will qualify as a “reorganization” under within the provisions meaning of Section 368(a) of the Code and (as defined below)ii) this Agreement be, and this Agreement it is intended to be and is hereby adopted as a “plan of reorganization” for purposes of Sections 354, 361, and 368 of the Code and within the meaning of Treasury Regulation Section Regulations Sections 1.368-2(g) and 1.368-3(a).

For U. S. federal income tax purposes, the Parties (as defined below) parties hereto intend for that the Merger (as defined below) provided for herein to will qualify as a “reorganization” under reorganization within the provisions meaning of Section 368(a) of the Code (as defined below), and the Company’s Board of Directors and the Boards of Directors of Parent and Merger Sub have approved this Agreement is intended to be and is adopted as intend that it constitute a “plan of reorganization” for purposes of Sections 354, 361, and 368 of the Code and reorganization within the meaning of Treasury Regulation Section 1.368-2(g).; and