Spin-Off Covenant. Agribrands shall have satisfied its post spin-off covenant to ▇▇▇▇▇▇▇ Purina by delivering to ▇▇▇▇▇▇▇ Purina (i) an opinion of tax counsel in form and substance satisfactory to ▇▇▇▇▇▇▇ Purina (which opinion shall recite that it may be relied upon by Ralcorp) or (ii) a supplemental ruling from the IRS that the transactions contemplated by this Agreement would not cause Agribrands' spin-off from ▇▇▇▇▇▇▇ Purina to be a taxable transaction.
Appears in 2 contracts
Sources: Agreement and Plan of Reorganization (Ralcorp Holdings Inc /Mo), Agreement and Plan of Reorganization (Agribrands International Inc)
Spin-Off Covenant. Agribrands shall have satisfied satisfy its post spin-off covenant ------------------ to ▇▇▇▇▇▇▇ Purina Company ("▇▇▇▇▇▇▇ Purina") by delivering to ▇▇▇▇▇▇▇ Purina (i) -------------- an opinion of tax counsel in form and substance satisfactory to ▇▇▇▇▇▇▇ Purina (which opinion shall recite that it may be relied upon by Ralcorp) or (ii) a supplemental ruling from the IRS that the transactions contemplated by this Agreement would not cause Agribrands' spin-off from ▇▇▇▇▇▇▇ Purina to be a taxable transaction.
Appears in 1 contract
Sources: Agreement and Plan of Reorganization (Ralcorp Holdings Inc /Mo)
Spin-Off Covenant. Agribrands shall have satisfied satisfy its post spin-spin- off covenant to ▇▇▇▇▇▇▇ Purina Company ("▇▇▇▇▇▇▇ Purina") by delivering to ▇▇▇▇▇▇▇ Purina (i) an opinion of tax counsel in form and substance satisfactory to ▇▇▇▇▇▇▇ Purina (which opinion shall recite that it may be relied upon by Ralcorp) or (ii) a supplemental ruling from the IRS that the transactions contemplated by this Agreement would not cause Agribrands' spin-off from ▇▇▇▇▇▇▇ Purina to be a taxable transaction.
Appears in 1 contract
Sources: Agreement and Plan of Reorganization (Agribrands International Inc)