Tax Effect. The parties intend that the Merger shall qualify as a tax-free reorganization under Section 368(a) of the Code.
Appears in 4 contracts
Samples: Merger Agreement (Sky Global Networks Inc), Merger Agreement (Gemstar Tv Guide International Inc), Merger Agreement (Liberty Media Corp /De/)
Tax Effect. The parties intend that each of the Merger Mergers shall qualify as a tax-free reorganization under within the meaning of Section 368(a) of the CodeCode and that this Agreement shall be and hereby is adopted by each of the parties as a plan of reorganization for purposes of Section 368 of the Code and the Treasury Regulations (as defined in Section 7.01 below) thereunder.
Appears in 3 contracts
Samples: Merger Agreement (Idt Corp), Merger Agreement (Liberty Media Corp /De/), Merger Agreement (Liberty Media Corp /De/)
Tax Effect. The parties intend that each of the Merger Mergers shall qualify as a tax-free reorganization under within the meaning of Section 368(a) of the CodeCode and that this Agreement shall be and hereby is adopted as a plan of reorganization for purposes of Section 368 of the Code and the Treasury Regulations (as defined in Section 7.01) thereunder.
Appears in 1 contract
