Tax Representations and Covenants. Each party represents that it is not aware of any fact that is in existence on the date hereof or may reasonably be expected to occur on or prior to the Closing, or has taken or agreed to take any action, that would reasonably be expected to prevent or impede (i) the Transaction from qualifying for the Intended Tax Treatment or (ii) the representations in the Tax Opinion Certificate from being true and correct on the date hereof or on the Closing Date.
Appears in 2 contracts
Samples: Equity Restructuring Agreement (HollyFrontier Corp), Equity Restructuring Agreement (Holly Energy Partners Lp)
Tax Representations and Covenants. (a) Each party Party represents that it is not aware of any fact that is in existence on the date hereof or may reasonably be expected to occur on or prior to the Closinghereof, or nor has it taken or agreed to take any action, that would reasonably be expected to prevent or impede (i) the Transaction transactions contemplated by this Agreement from qualifying for the Intended Agreed Tax Treatment or (ii) the representations in the Tax Opinion Certificate from being true and correct on the date hereof or on the Closing DateTreatment.
Appears in 2 contracts
Samples: Equity Restructuring Agreement (DCP Midstream, LP), Equity Restructuring Agreement (CrossAmerica Partners LP)
Tax Representations and Covenants. (a) Each party Party represents that it is not aware of any fact that is in existence on the date hereof or may reasonably be expected to occur on or prior to the Closing, or has taken or agreed to take any action, that would reasonably be expected to prevent or impede (i) the Transaction Transactions from qualifying for the Intended Agreed Tax Treatment or (ii) the representations in the Tax Opinion Certificate from being true and correct on the date hereof or on the Closing DateTreatment.
Appears in 1 contract
Samples: Equity Restructuring Agreement (Spectra Energy Partners, LP)