Common use of Tax Treatment of Merger Clause in Contracts

Tax Treatment of Merger. It is intended that, for U.S. federal income tax purposes, the Merger shall qualify as a “reorganization” within the meaning of Section 368(a) of the Code, and that this Agreement constitutes, and hereby is adopted as, a “plan of reorganization” within the meaning of Treasury Regulations Sections 1.368-2(g) and 1.368-3.

Tax Treatment of Merger. It is intended that, for U.S. federal income tax purposes, the The Merger (a) shall qualify as a “reorganization” within the meaning of tax-free reorganization under Section 368(a368(a)(1)(A) of the CodeCode by virtue of Section 368(a)(2)(D) of the Code and (b) shall not result in gain or loss to the extent provided in Sections 354, 356, and that this 361 of the Code. This Agreement constitutes, and hereby is adopted as, intended to constitute a “plan of reorganization” within the meaning of Treasury Regulations Sections Section 1.368-2(g) and 1.368-3).

Tax Treatment of Merger. It is intended that, for For U.S. federal income tax purposes, the Parties intend that (i) the Merger shall qualify as a “reorganization” reorganization within the meaning of Section 368(a) of the Code, Code and that the Treasury Regulations promulgated thereunder and (ii) this Agreement constitutes, and hereby is adopted as, constitute a “plan of reorganization” within the meaning of Treasury Regulations Sections §§ 1.368-2(g) and 1.368-33(a).