Common use of Reorganization for Tax Purposes Clause in Contracts

Reorganization for Tax Purposes. The Merger is intended to be treated for U.S. federal income tax purposes as a “reorganization” described in Section 368(a)(1)(F) of the Internal Revenue Code of 1986, as amended, and by executing this agreement the parties intend to adopt a “plan of reorganization” within the meaning of Sections 1.368-2(g) and 1.368-3(a) of the Treasury Regulations.

Reorganization for Tax Purposes. The This Merger Agreement is intended to be treated for U.S. federal income tax purposes as constitute a “reorganization” described in plan of reorganization adopted by the parties hereto within the meaning of Section 368(a)(1)(F) 368 of the Internal Revenue Code of 1986, as amendedamended (the “Code”), and by executing this agreement the parties intend regulations promulgated thereunder. The Merger is intended to adopt constitute a “plan of reorganization” reorganization within the meaning of Sections 1.368-2(g) and 1.368-3(a) of the Treasury RegulationsCode Section 368(a)(1)(F).

Reorganization for Tax Purposes. The This Merger Agreement is intended to be treated for U.S. federal income tax purposes as constitute a “reorganization” described in plan of reorganization adopted by the parties hereto within the meaning of Section 368(a)(1)(F) 368 of the Internal Revenue Code of 1986, as amended, amended (the “Code”) and by executing this agreement the parties intend regulations promulgated thereunder. The Merger is intended to adopt constitute a “plan of reorganization” reorganization within the meaning of Sections 1.368-2(g) and 1.368-3(a) of the Treasury RegulationsCode Section 368(a)(1)(F).

Reorganization for Tax Purposes. The Merger is intended to be treated for U.S. federal income tax purposes qualify as a “reorganization” described in within the meaning of Section 368(a)(1)(F) of the Internal Revenue Code of 1986, as amendedCode, and by executing this agreement the parties intend Agreement is intended to adopt constitute, and is hereby adopted as, a “plan of reorganization” within the meaning of Section 368 of the Code and Treasury Regulations Sections 1.368-1(c), 1.368-2(g) and 1.368-3(a) of the Treasury Regulations).