Tax Free Status. SpinCo hereby represents and warrants that neither SpinCo nor any other member of the SpinCo Group has a plan or intention of taking any action, or failing to take any action, or knows of any circumstance, that could reasonably be expected to (A) cause any of the Spin-Off-Related Transactions not to have Tax-Free Status or (B) cause any representation or factual statement made in this Agreement, the Separation and Distribution Agreement or the Tax Opinion Documents to be untrue in a manner that would have an adverse effect on the Tax-Free Status of any of the Spin-Off-Related Transactions.
Appears in 3 contracts
Samples: Tax Sharing Agreement, Tax Sharing Agreement (Marathon Petroleum Corp), Tax Sharing Agreement (Marathon Petroleum Corp)
