Common use of Qualification as Reorganization Clause in Contracts

Qualification as Reorganization. For U.S. federal income tax purposes, (1) each step of the Restructuring is generally intended to be undertaken in a manner so that no gain or loss is recognized (and no income is taken into account) by LIC, Spinco or their respective Subsidiaries, and (2) the Contribution and the Distribution are intended to qualify as a tax-free reorganization under Sections 368(a) and 355 of the Code.

Qualification as Reorganization. For U.S. federal income tax purposes, (1) each step of the Restructuring (together with all conversions, contributions and distributions contemplated by Schedule 1.1 to occur in connection therewith) is generally intended to be undertaken in a manner so that no gain or loss is recognized (and no income is taken into account) by LIC, Spinco or their respective Subsidiariesrecognized, and (2) the Contribution and the Distribution are Redemption is intended to qualify as a tax-free reorganization under Sections 368(a) and 355 of the Code.

Qualification as Reorganization. For U.S. federal income tax purposes, (1) each step of the Restructuring is generally intended to be undertaken in a manner so that no gain or loss is recognized (and no income is taken into account) by LICLMC, Spinco or their respective Subsidiaries, and (2) the Contribution and the Distribution are intended to qualify as a tax-free reorganization under Sections 368(a) and 355 of the Code.

Qualification as Reorganization. For U.S. federal income tax purposes, (1) each step of the Restructuring is generally intended to be undertaken in a manner so that no gain or loss is recognized (and no income is taken into account) by LICBW, Spinco Republic Wireless or their respective Subsidiaries, and (2) the Contribution and the Distribution are intended to qualify as a tax-free reorganization under Sections 368(a) and 355 of the Code.

Qualification as Reorganization. For U.S. federal income tax purposes, (1) each step of the Restructuring is generally intended to be undertaken in a manner so that no gain or loss is recognized (and no income is taken into account) by LICLMC, Spinco or their respective Subsidiaries, and (2) the Contribution and the Distribution are intended to qualify as a tax-free reorganization under Sections 368(a) and 355 of the Code.

Qualification as Reorganization. For U.S. federal income tax purposes, (1) each step of the Restructuring Restructuring, other than Step 9 with respect to the distribution by LTWX V, Inc., is generally intended to be undertaken in a manner so that no gain or loss is recognized (and no income is taken into account) by LICLMC, Spinco Splitco or their respective Subsidiaries, and (2) the Contribution and the Distribution Redemptions are intended to qualify as a tax-free reorganization under Sections 368(a) and 355 of the Code.

Qualification as Reorganization. For U.S. federal income tax purposes, (1) each step of the Restructuring is generally intended to be undertaken in a manner so that no gain or loss is recognized (and no income is taken into account) by LIC, Spinco Splitco or their respective Subsidiaries, and (2) the Contribution and the Distribution Redemption are intended to qualify as a tax-free reorganization under Sections 368(a368(a)(1)(D) and 355 of the Code.

Qualification as Reorganization. For U.S. federal income tax purposes, (1) each step of Step through Step in the Restructuring is Plan are generally intended to be undertaken in a manner so that no gain or loss is recognized (and no income is taken into account) by LIC, Spinco or their respective Subsidiaries, and (2) the Contribution and the Distribution are Spin-Off is intended to qualify as a tax-free reorganization transaction under Sections 368(a) and Section 355 of the CodeCode (except with respect to the receipt of cash in lieu of fractional shares).

Qualification as Reorganization. For U.S. federal income tax Tax purposes, (1a) each step of the Restructuring is generally intended to be undertaken in a manner so that no gain or loss is recognized (and no income is taken into account) by LICParent, Spinco or their respective Subsidiaries, and so that shareholders of Parent recognize gain only to the extent that they receive cash in lieu of fractional shares, and (2b) the Contribution Contribution, the Distribution and the Distribution other steps described herein are intended to qualify as a tax-free reorganization under transactions that are described in Sections 368(a368(a)(1)(D) and 355 of the Code.

Qualification as Reorganization. For U.S. federal income tax purposes, (1) each step of the Restructuring (together with all conversions, contributions and distributions contemplated by Schedule 1.1 to occur in connection therewith) is generally intended to be undertaken in a manner so that no gain or loss is recognized (and no income is taken into account) by LIC, Spinco or their respective Subsidiariesrecognized, and (2) the Contribution and the Distribution are Redemption is intended to qualify as a tax-free reorganization under Sections 368(a) and 355 of the Code.

Qualification as Reorganization. For U.S. federal income tax purposes, (1) each step of the Restructuring is generally intended to be undertaken in a manner so that no gain or loss is recognized (and no income is taken into account) by LICLMC, Spinco Splitco or their respective Subsidiaries, and (2) the Contribution and the Distribution Redemptions are intended to qualify as a tax-free reorganization under Sections 368(a) and 355 of the Code.