Tax Reporting of Transaction. For federal income tax purposes, the Parties agree to report the transactions effectuated by this Agreement as follows:
Tax Reporting of Transaction. It is the intention and expectation of the parties to this Agreement that, for federal and state income tax purposes, the purchase of the Recyc Stock will result in and be reported as a taxable sale and purchase of the assets of Recyc (whether actual or deemed pursuant to Proposed Treasury Regulation Section 1.1361-5(b)(3) Ex (1)) by the Shareholder and Synagro, respectively. The parties acknowledge that Synagro would not proceed with the purchase of the Recyc Stock without such income tax treatment. The parties to this Agreement intend to report the purchase and sale of the Recyc Stock as a taxable sale of all the assets of Recyc for federal and state income tax purposes on a basis consistent with Code Section 1060, and expect that no election need be made under Code Section 338(h)(10).
Tax Reporting of Transaction. (a) For federal income tax purposes, the Parties acknowledge that for U.S. federal, and applicable state and local income Tax purposes the transactions contemplated by this Agreement will be treated as a sale by Seller and a purchase by Purchaser of a partnership interest in TE Holdco.
