Tax Character. The parties agree that any payments made to IEP pursuant to this Article VIII will be treated for federal and state income tax purposes as a tax-free contribution to IEP in exchange for the Exchange Units under Code Section 721(a) and no party, on a Tax Return or otherwise, shall, except to the extent required by Law, take any position inconsistent with such treatment.
Appears in 2 contracts
Samples: Contribution and Exchange Agreement (Icahn Enterprises Holdings L.P.), Contribution and Exchange Agreement (Icahn Enterprises L.P.)
Tax Character. The parties agree that any payments made to IEP pursuant to this Article VIII IX will be treated for federal and state income tax purposes as a tax-free contribution to IEP in exchange for the Exchange Units under Code Section 721(a) and no party, on a Tax Return or otherwise, shall, except to the extent required by Law, take any position inconsistent with such treatment.
Appears in 2 contracts
Samples: Contribution and Exchange Agreement (Icahn Enterprises L.P.), Contribution and Exchange Agreement (Icahn Enterprises L.P.)
