Common use of TAX STATUS OF REORGANIZATION Clause in Contracts

TAX STATUS OF REORGANIZATION. The intention of the parties is that the transactions contemplated by this Agreement will qualify as a reorganization within the meaning of Section 368(a) of the Code. Neither the Acquiring Portfolio nor the Target Portfolio shall take any action, or cause any action to be taken (including, without limitation, the filing of any tax return) that is inconsistent with such treatment or results in the failure of the transaction to qualify as a reorganization within the meaning of Section 368(a) of the Code. At or prior to the Closing Date, the Acquiring Portfolio and the Target Portfolio will take such action, or cause such action to be taken, as is reasonably necessary to enable Skadden, Arps, Slate, Xxxxxxx & Xxxx LLP (“Xxxxxxx Xxxx”), special counsel to the Acquiring Portfolio and the Target Portfolio, to render the tax opinion required herein (including, without limitation, each party’s execution of representations reasonably requested by Xxxxxxx Xxxx).

TAX STATUS OF REORGANIZATION. The intention of the parties is that the transactions contemplated by this Agreement will qualify as a reorganization within the meaning of Section 368(a) of the Code. Neither the Acquiring Portfolio nor the Target Portfolio shall take any action, or cause any action to be taken (including, without limitation, the filing of any tax return) that is inconsistent with such treatment or results in the failure of the transaction to qualify as a reorganization within the meaning of Section 368(a) of the Code. At or prior to the Closing Date, the Acquiring Portfolio and the Target Portfolio will take such action, or cause such action to be taken, as is reasonably necessary to enable Skadden, Arps, Slate, Xxxxxxx & Xxxx Xxxxx LLP (“Xxxxxxx XxxxXxxx Xxxxx”), special counsel to the Acquiring Portfolio and the Target Portfolio, to render the tax opinion required herein (including, without limitation, each party’s execution of representations reasonably requested by Xxxxxxx XxxxXxxx Xxxxx).

TAX STATUS OF REORGANIZATION. The intention of the parties is that the transactions contemplated by this Agreement will qualify as a reorganization within the meaning of Section 368(a) of the Code. Neither the Acquiring Portfolio Fund nor the Target Portfolio Fund shall take any action, or cause any action to be taken (including, without limitation, the filing of any tax return) that is inconsistent with such treatment or results in the failure of the transaction to qualify as a reorganization within the meaning of Section 368(a) of the Code. At or prior to the Closing Date, the Acquiring Portfolio Fund and the Target Portfolio Fund will take such action, or cause such action to be taken, as is reasonably necessary to enable Skadden, Arps, Slate, Xxxxxxx & Xxxx Xxxxx LLP (“Xxxxxxx XxxxXxxx Xxxxx”), special counsel to the Acquiring Portfolio Fund and the Target PortfolioFund, to render the tax opinion required herein (including, without limitation, each party’s execution of representations reasonably requested by Xxxxxxx XxxxXxxx Xxxxx).

TAX STATUS OF REORGANIZATION. The intention of the parties is that the transactions contemplated by this Agreement will qualify as a reorganization within the meaning of Section 368(a) of the Code. Neither the Acquiring Portfolio nor the Target Portfolio shall take any action, or cause any action to be taken (including, without limitation, the filing of any tax return) that is inconsistent with such treatment or results in the failure of the transaction to qualify as a reorganization within the meaning of Section 368(a) of the Code. At or prior to the Closing Date, the Acquiring Portfolio and the Target Portfolio will take such action, or cause such action to be taken, as is reasonably necessary to enable Skadden, Arps, Slate, Xxxxxxx & Xxxx Xxxxx LLP (“Xxxxxxx XxxxXxxx Xxxxx”), special counsel to the Acquiring Portfolio and the Target Portfolio, to render the tax opinion required herein (including, without limitation, each party’s execution of representations reasonably requested by Xxxxxxx XxxxXxxx Xxxxx).

TAX STATUS OF REORGANIZATION. The intention of the parties is that the transactions contemplated by this Agreement will qualify as a reorganization within the meaning of Section 368(a) of the Code. Neither the Acquiring Portfolio Fund nor the Target Portfolio Fund shall take any action, or cause any action to be taken (including, without limitation, the filing of any tax return) that is inconsistent with such treatment or results in the failure of the transaction to qualify as a reorganization within the meaning of Section 368(a) of the Code. At or prior to the Closing Date, the Acquiring Portfolio Fund and the Target Portfolio Fund will take such action, or cause such action to be taken, as is reasonably necessary to enable Skadden, Arps, Slate, Xxxxxxx & Xxxx Xxxxx LLP (“Xxxxxxx XxxxXxxx Xxxxx”), special counsel to the Acquiring Portfolio Fund and the Target PortfolioFund, to render the tax opinion required herein (including, without limitation, each party’s execution of representations reasonably requested by Xxxxxxx XxxxXxxx Xxxxx).