Common use of Reorganization Treatment Clause in Contracts

Reorganization Treatment. It is intended that for U.S. federal income tax purposes, the Merger shall qualify as a “reorganization” within the meaning of Section 368(a) of the Code and the Treasury Regulations promulgated thereunder, and this Agreement is hereby adopted as a “plan of reorganization” for purposes of Sections 354, 361 and 368 of the Code and Treasury Regulations Sections 1.368-2(g) and 1.368-3(a).

Reorganization Treatment. It is intended that for U.S. For federal income tax purposes, each of the Mergers is intended to constitute a reorganization within the meaning of Section 368(a) of the Code. For the avoidance of doubt, and not withstanding anything herein to the contrary, no Party represents, warrants or guarantees that the Merger shall qualify and the transactions contemplated by this Agreement will be treated by any relevant regulatory authority as a “reorganization” reorganization within the meaning of Section 368(a) of the Code and the Treasury Regulations promulgated thereunder, and parties intend for this Agreement is hereby adopted as to constitute a “plan of reorganization” for purposes within the meaning of Sections 354, 361 and 368 of the Code and Treasury Regulations Sections 1.368-2(g) and 1.368-3(a)) of the United States Treasury Regulations.

Reorganization Treatment. It is intended that for U.S. federal income tax purposes, the Merger shall qualify as a “reorganization” within the meaning of Section 368(a) of the Code and the Treasury Regulations promulgated thereunderCode, and this Agreement is hereby adopted as a “plan of reorganization” for purposes within the meaning of Sections 354, 361 and 368 of the Code and Treasury Regulations Sections 1.368-2(g) and 1.368-3(a).