Common use of Preservation of Tax Treatment Clause in Contracts

Preservation of Tax Treatment. (a) Except as contemplated by this Agreement or the Registration Statement, after the Funding and Consummation Date, QSI shall not and shall not permit any of its subsidiaries to undertake any act that would prevent qualification of the transaction as an exchange meeting the requirements of Code Section 351, including: (i) the retirement or reacquisition, directly or indirectly, of all or part of the QSI Stock issued in connection with the transactions contemplated hereby; or (ii) the entering into of financial arrangements for the benefit of the Stockholders. (b) Except as contemplated by this Agreement or the Registration Statement, after the Funding and Consummation Date, the Stockholders shall not undertake any act that would prevent qualification of the transaction as an exchange meeting the requirements of Code Section 351. (c) Each of the Company, QSI and each Stockholder shall comply with the reporting requirements of Section 1.351-3 of the Treasury Regulations promulgated under the Code, and shall not take any position on any Return inconsistent with characterization of the transaction as an exchange meeting the requirements of Code Section 351.

Preservation of Tax Treatment. (a) Except as contemplated by this Agreement or the Registration Statement, after the Funding and Consummation Date, QSI shall not and shall not permit any of its subsidiaries to undertake any act that would prevent qualification of the transaction as an exchange meeting the requirements of Code Section 351, including: (i) the retirement or reacquisition, directly or indirectly, of all or part of the QSI Stock issued in connection with the transactions contemplated hereby; or (ii) the entering into of financial arrangements for the benefit of the StockholdersStockholder. (b) Except as contemplated by this Agreement or the Registration Statement, after the Funding and Consummation Date, the Stockholders Stockholder shall not undertake any act that would prevent qualification of the transaction as an exchange meeting the requirements of Code Section 351. (c) Each of the Company, QSI and each Stockholder shall comply with the reporting requirements of Section 1.351-3 of the Treasury Regulations promulgated under the Code, and shall not take any position on any Return inconsistent with characterization of the transaction as an exchange meeting the requirements of Code Section 351.