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: Agreement and Plan of Merger (Navios Maritime Partners L.P.), Agreement and Plan of Merger (Navios Maritime Containers L.P.), Agreement and Plan of Merger (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, Agreement and Plan of Merger (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 4 contracts
Samples: Agreement and Plan of Merger (Sano Corp), Agreement and Plan of Merger (General Electric Co), Agreement and Plan of Merger (Target Therapeutics Inc)
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.)
Plan of Reorganization. For purposes This Agreement is intended to constitute a "plan of reorganizations within the meaning of Section 1.368-2(g) of the Intended Tax Treatment, this Agreement constitutes, and is adopted as, a “plan of reorganization” for purposes of Sections 354 and 361 of income tax regulations promulgated under the Code.
Appears in 1 contract
Samples: Agreement and Plan of Merger (Greenwich Air Services Inc)
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. SECTION 6.11.
Appears in 1 contract
