Reincorporation. The Reincorporation (a) qualified as a reorganization under Section 368(a)(1)(F) of the Code or (b) was a non-event for federal income tax purposes, and no gain or loss was or will be recognized by the Company for federal income tax purposes as a result of the Reincorporation.
Appears in 3 contracts
Samples: Underwriting Agreement (Realty Income Corp), Purchase Agreement (Realty Income Corp), Underwriting Agreement (Realty Income Corp)
Reincorporation. The Reincorporation will be treated as (a) qualified as a reorganization under Section 368(a)(1)(F) of the Code or (b) was a non-event for federal income tax purposes, and no gain or loss was or will be recognized by the Company for federal income tax purposes as a result of the Reincorporation.
Appears in 1 contract
Samples: Realty Income Corp
