Plan of Reorganization. For purposes of the Intended Tax Treatment, this Agreement constitutes, and is adopted as, a “plan of reorganization” for purposes of Sections 354 and 361 of the Code.
Appears in 7 contracts
Samples: Merger Agreement (Navios Maritime Partners L.P.), Merger Agreement (Navios Maritime Containers L.P.), Merger Agreement (Navios Maritime Partners L.P.)
Plan of Reorganization. For purposes of the Intended Tax TreatmentU.S. federal income tax purposes, this Agreement constitutes, and is adopted as, shall constitute a “plan of reorganization” for purposes within the meaning of Sections 354 and 361 Section 368 of the CodeCode and the Treasury Regulations promulgated thereunder.
Appears in 6 contracts
Samples: Master Separation Agreement, Merger Agreement (D.E Master Blenders 1753 N.V.), Master Separation Agreement (Sara Lee Corp)
Plan of Reorganization. For purposes of the Intended Tax Treatment, this This Agreement constitutes, and is adopted as, intended to constitute a “"plan of reorganization” for purposes " within the meaning of Sections 354 and 361 Section 1.368-2(g) of the income tax regulations promulgated under the Code.
Appears in 5 contracts
Samples: Merger Agreement (Sano Corp), Merger Agreement (Target Therapeutics Inc), Merger Agreement (General Electric Co)
Plan of Reorganization. For purposes of the Intended Tax TreatmentU.S. federal income tax purposes, this Agreement constitutes, and is adopted as, will constitute a “"plan of reorganization” for purposes " within the meaning of Sections 354 and 361 Section 368 of the CodeCode and the Treasury Regulations promulgated thereunder.
Appears in 4 contracts
Samples: Reorganization Agreement (Fidelity National Financial, Inc.), Reorganization Agreement (Liberty Entertainment, Inc.), Reorganization Agreement (Liberty Entertainment, Inc.)
