Common use of Intended Tax Treatment Clause in Contracts

Intended Tax Treatment. The parties intend the Merger to be treated as a reorganization under Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and the rules and regulations thereunder, and intend for this Agreement to constitute a “plan of reorganization” within the meaning of the Code.

Appears in 3 contracts

Samples: Merger Agreement (Edwards a G Inc), Merger Agreement (Main Street Trust Inc), Merger Agreement (Wachovia Corp New)

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Intended Tax Treatment. The parties intend It is intended that the Merger to be treated shall qualify as a reorganization under “reorganization” within the meaning of Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and the rules and regulations thereunderthat this Agreement is intended to be, and intend for this Agreement to constitute is adopted as, a “plan of reorganization” within the meaning for purposes of Sections 354 and 361 of the Code.

Appears in 3 contracts

Samples: Merger Agreement (Rock-Tenn CO), Merger Agreement (SMURFIT-STONE CONTAINER Corp), Merger Agreement (Rock-Tenn CO)

Intended Tax Treatment. The parties intend It is intended that the Merger to be treated Mergers, taken together, shall qualify as a reorganization under “reorganization” within the meaning of Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and that the rules Acquisition Agreement and regulations thereunder, and intend for this Agreement to shall together constitute and are adopted as a “plan of reorganization” within the meaning of the CodeTreasury Regulations §§ 1.368-2(g) and 1.368-3(a).

Appears in 2 contracts

Samples: Merger Agreement (Chesapeake Energy Corp), Merger Agreement (WildHorse Resource Development Corp)

Intended Tax Treatment. The parties intend It is intended that the Merger to be treated shall qualify as a reorganization under “reorganization” within the meaning of Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and the rules and regulations thereunderthat this Agreement be, and intend for this Agreement to constitute hereby is, adopted as a “plan of reorganization” for purposes of Sections 354, 361 and 368 of the Code and within the meaning of Treas. Reg. §§ 1.368-2(g) and 1.368-3(a) (the Code.“Intended Tax Treatment”). Article III MERGER CONSIDERATION; CONVERSION OF SECURITIES

Appears in 2 contracts

Samples: Merger Agreement (LMF Acquisition Opportunities Inc), Merger Agreement (LMF Acquisition Opportunities Inc)

Intended Tax Treatment. The parties intend It is intended that the Merger to be treated Mergers, taken together, shall qualify as a reorganization under Section 368(a) of the Internal Revenue Code of 1986, as amended (the Code”), and the rules and regulations thereunder, and intend for this Agreement to constitute a “plan of reorganization” within the meaning of Section 368(a) of the Code, and that the Merger Agreement is intended to be a plan of reorganization for purposes of Sections 354 and 361 of the Code and within the meaning of Treasury Regulations Section 1.368-2(g) and 1.368-3(a).

Appears in 2 contracts

Samples: Merger Agreement (Keane Group, Inc.), Merger Agreement (C&J Energy Services, Inc.)

Intended Tax Treatment. The parties intend It is intended that the Merger to be treated Mergers, taken together, shall qualify as a reorganization under “reorganization” within the meaning of Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and that the rules and regulations thereunder, and intend for this Merger Agreement to constitute constitutes a “plan of reorganization” within the meaning of the CodeTreasury Regulations §§ 1.368-2(g) and 1.368-3(a).

Appears in 2 contracts

Samples: Merger Agreement (Midstates Petroleum Company, Inc.), Merger Agreement (Amplify Energy Corp)

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Intended Tax Treatment. The parties intend It is intended that the Merger to be treated will qualify as a reorganization under “reorganization” within the meaning of Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and the rules and regulations thereunderthat this Agreement is intended to be, and intend for this Agreement to constitute is adopted as, a “plan of reorganization” within the meaning for purposes of Sections 354 and 361 of the Code.

Appears in 1 contract

Samples: Merger Agreement (American Homes 4 Rent)

Intended Tax Treatment. The parties intend It is intended that the Merger to be treated Mergers, taken together, shall qualify as a reorganization under “reorganization” within the meaning of Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and that the rules Acquisition Agreement and regulations thereunder, and intend for this Agreement to shall together constitute and be adopted as a “plan of reorganization” within the meaning of the CodeTreasury Regulations §§ 1.368-2(g) and 1.368-3(a).

Appears in 1 contract

Samples: Merger Agreement (EQT Corp)

Intended Tax Treatment. The parties intend It is intended that the Merger to be treated as shall constitute a reorganization under “reorganization” within the meaning of Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and the rules and regulations thereunder, and intend for that this Agreement to shall constitute a “plan of reorganization” within the meaning for purposes of Sections 354 and 361 of the Code.

Appears in 1 contract

Samples: Merger Agreement (Digital Cinema Destinations Corp.)

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