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 BW, 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.
Appears in 2 contracts
Samples: Reorganization Agreement, Reorganization Agreement (Bandwidth Inc.)
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 BWLIC, Republic Wireless 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.
Appears in 2 contracts
Samples: Reorganization Agreement (Liberty Expedia Holdings, Inc.), Reorganization Agreement (Liberty Expedia Holdings, Inc.)
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 BWLMC, Republic Wireless 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.
Appears in 2 contracts
Samples: Reorganization Agreement (Liberty Broadband Corp), Reorganization Agreement (Starz)
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 BWLIC, Republic Wireless 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.
Appears in 2 contracts
Samples: Reorganization Agreement (Liberty Interactive Corp), Reorganization Agreement (Liberty TripAdvisor Holdings, Inc.)
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 BW, Republic Wireless 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.
Appears in 2 contracts
Samples: Reorganization Agreement (Liberty Entertainment, Inc.), Reorganization Agreement (Liberty Entertainment, Inc.)
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 BWLMC, Republic Wireless 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.
Appears in 2 contracts
Samples: Reorganization Agreement (Liberty Spinco, Inc.), Reorganization Agreement (Liberty Spinco, Inc.)
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 BW, Republic Wireless 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.
Appears in 1 contract
Samples: Reorganization Agreement (Liberty Entertainment, Inc.)
