Qualification as Reorganization. (a) For U.S. federal income tax purposes, LGP and Splitco intend that (1) the PR Spin-off qualifies as tax-free under Section 355 of the Code, and (2) the Split-off qualifies as a tax-free reorganization and split-off transaction under Sections 368(a)(1)(D) and 355 and related provisions of the Code.
Appears in 4 contracts
Samples: Reorganization Agreement, Reorganization Agreement (Liberty Latin America Ltd.), Reorganization Agreement (Liberty Latin America Ltd.)