Representations, Covenants, and Agreements. (a) The parties expressly agree for all purposes to treat the Distribution as a tax-free distribution under section 355 and related sections of the Code, including section 361(c) of the Code (“Section 355 Tax Treatment”).
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Samples: Form of Tax Disaffiliation Agreement (Lender Processing Services, Inc.), Form of Tax Disaffiliation Agreement (Lender Processing Services, Inc.), Tax Disaffiliation Agreement (Fidelity National Information Services, Inc.)