No Intermediary Transaction Tax Shelter. Buyer shall not take any action with respect to the Target subsequent to the Closing that would cause any of the Transactions to constitute part of a transaction that is the same as, or substantially similar to, the “Intermediary Transaction Tax Shelter” described in Internal Revenue Service Notices 2001-16 and 2008-111.
Appears in 5 contracts
Samples: Interest Purchase Agreement (Energy 11, L.P.), Interest Purchase Agreement (Energy 11, L.P.), Interest Purchase Agreement (Energy 11, L.P.)
No Intermediary Transaction Tax Shelter. After the Closing, Buyer shall not take any action (and shall cause its Affiliates not to take any action) with respect to the Target subsequent to the Closing Companies or Subsidiaries that would cause any of the Transactions transactions contemplated by this Agreement to constitute part of a transaction that is the same as, or substantially similar to, the “Intermediary Transaction Tax Shelter” described in Internal Revenue Service IRS Notices 2001-16 and 2008-111.
Appears in 2 contracts
Samples: Share Purchase Agreement (Emerson Electric Co), Share Purchase Agreement (PENTAIR PLC)
No Intermediary Transaction Tax Shelter. Buyer shall not has no plan or intention to take any action with respect to the Target IPG Entities subsequent to the Closing that would cause any of the Transactions transaction contemplated hereby to constitute part of a transaction that is the same as, or substantially similar to, the “Intermediary Transaction Tax Shelter” described in Internal Revenue Service Notices 2001-16 and 2008-111.
Appears in 2 contracts
Samples: Stock Purchase Agreement, Stock Purchase Agreement (Illinois Tool Works Inc)
No Intermediary Transaction Tax Shelter. Buyer The Purchaser shall not take any action or cause any action to be taken with respect to the Target Surviving Corporation subsequent to the Closing that would cause any of the Transactions transactions contemplated hereby to constitute part of a transaction that is the same as, or substantially similar to, the “"Intermediary Transaction Tax Shelter” " described in Internal Revenue Service Notices Notice 2001‑16, 2001-16 and 1 C.B. 730 as clarified by Notice 2008‑111, 2008-1112 C.B. 1299.
Appears in 1 contract
No Intermediary Transaction Tax Shelter. Buyer shall not take any action with respect to the Target Acquired Companies subsequent to the Closing that would cause any of the Transactions transactions contemplated hereby to constitute part of a transaction that is the same as, or substantially similar to, the “Intermediary Transaction Tax Shelter” described in Internal Revenue Service Notices 2001-16 and 2008-111.
Appears in 1 contract
Samples: Purchase Agreement (Hardinge Inc)
No Intermediary Transaction Tax Shelter. Buyer shall not has no plan or intention to take any action with respect to the Target Nutra subsequent to the Initial Closing that would cause any of the Transactions transaction contemplated hereby to constitute part of a transaction that is the same as, or substantially similar to, the “Intermediary Transaction Tax Shelter” described in Internal Revenue Service Notices 2001-16 and 2008-111.
Appears in 1 contract
