Tax Treatment of Founder Share Conversion. The Parties intend that the Founder Share Conversion will be treated as a tax-free recapitalization under Section 368(a)(1)(E) of the Internal Revenue Code of 1986, as amended.
Appears in 5 contracts
Samples: Business Combination Agreement (Artisan Acquisition Corp.), Business Combination Agreement (Artisan Acquisition Corp.), Sponsor Agreement (Cohn Robbins Holdings Corp.)