Tax Shelters; Listed Transactions; Etc. Neither the Company nor any Subsidiary has consummated or participated in, nor is the Company or any Subsidiary currently participating in, any transaction which was or is a “tax shelter” transaction as defined in Sections 6662 or 6111 of the Code or the Treasury Regulations promulgated thereunder. Neither the Company nor any Subsidiary has ever participated in, nor is currently participating in, a “Listed Transaction” or a “Reportable Transaction” within the meaning of Section 6707A(c) of the Code or Treasury Regulation Section 1.6011-4(b), or any transaction requiring disclosure under a corresponding or similar provision of state, local, or foreign Legal Requirements. The Company and each Subsidiary has disclosed on its Tax Returns any Tax reporting position taken in any Tax Return which could result in the imposition of penalties under Section 6662 of the Code (or any comparable provisions of state, local or foreign law).
Appears in 2 contracts
Samples: Agreement and Plan of Merger, Agreement and Plan of Merger (Salesforce Com Inc)
Tax Shelters; Listed Transactions; Etc. Neither the Company nor any Subsidiary has of its Subsidiaries have consummated or participated in, nor is the Company or any Subsidiary of its Subsidiaries currently participating in, any transaction which was or is a “tax shelter” transaction as defined in Sections Section 6662 or 6111 of the Code or and the Treasury Regulations promulgated thereunder. Neither the Company nor any Subsidiary has of its Subsidiaries have ever participated in, nor is currently participating in, a “Listed Transaction” or a “Reportable Transactionlisted transaction” within the meaning of Section 6707A(c) of the Code or Treasury Regulation Regulations Section 1.6011-4(b), or any transaction requiring disclosure under a corresponding or similar provision of state, local, or foreign Legal Requirements. The Company and each Subsidiary of its Subsidiaries has disclosed on its respective Tax Returns any Tax reporting position taken in any Tax Return which could reasonably be expected to result in the imposition of penalties under Section 6662 of the Code (or any comparable provisions of state, local or foreign lawnon-U.S. Legal Requirements).
Appears in 2 contracts
Samples: Agreement and Plan of Merger and Reorganization (Coupa Software Inc), Agreement and Plan of Merger and Reorganization (Crexendo, Inc.)
Tax Shelters; Listed Transactions; Etc. Neither the Company nor any Subsidiary has consummated or participated in, nor is the Company or any Subsidiary currently participating in, any transaction which was or is a “tax shelter” transaction as defined in Sections 6662 or 6111 of the Code or the Treasury Regulations promulgated thereunder. Neither the Company nor any Subsidiary has ever participated in, nor is currently participating in, a “Listed Transaction” or a “Reportable Transaction” within the meaning of Section 6707A(c) of the Code or Treasury Regulation Section 1.6011-4(b), or any transaction requiring disclosure under a corresponding or similar provision of U.S. state, local, or foreign non-U.S. Legal Requirements. The Company and each Subsidiary has disclosed on its Tax Returns any Tax reporting position taken in any Tax Return which could result in the imposition of penalties under Section 6662 of the Code (or any comparable provisions of U.S. state, local or foreign non-U.S. law).
Appears in 2 contracts
Samples: Agreement and Plan of Reorganization (GOOD TECHNOLOGY Corp), Agreement and Plan of Reorganization (GOOD TECHNOLOGY Corp)
