Tax Shelters. No Acquired Company has consummated or participated in, or is 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. Each Acquired Company has not participated in, and is not 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 law.
Appears in 2 contracts
Samples: Agreement and Plan of Merger (Yelp Inc), Agreement and Plan of Merger (Yelp Inc)
Tax Shelters. No Acquired The Company has not consummated or participated in, or and is not 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. Each Acquired The Company has not participated in, and is not 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 law.
Appears in 2 contracts
Samples: Agreement and Plan of Merger, Agreement and Plan of Merger (Yelp Inc)
Tax Shelters. No Acquired Company has consummated or participated in, or is 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. Each Acquired The Company has not participated in, and is not currently participating in, or engaged in a transaction that either constitutes a “Listed Transactionlisted transaction” or a “Reportable Transactionreportable 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, local or foreign law. The Company has disclosed on its U.S. federal income Tax Returns all positions taken therein with respect to the Company that could give rise to a “substantial understatement of income tax” within the meaning of Section 6662 of the Code (or any corresponding or similar provision of state, local or foreign law).
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