Tax Treatment of Merger. The parties agree to treat the Merger for U.S. federal income tax purposes as a tax-free reorganization under Sections 351 and/or 368 of the Code.
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Samples: Agreement and Plan of Merger (SAIC, Inc.), Agreement and Plan of Merger (Science Applications International Corp), Agreement and Plan of Merger (Science Applications International Corp)
Tax Treatment of Merger. The parties agree to treat that the Merger will be treated for U.S. federal income tax purposes as a tax-free reorganization under pursuant to Section 368(a) of the Code (the “Reorganization”). This Agreement is intended to constitute, and the parties hereto hereby adopt this Agreement as, a “plan of reorganization” for purposes of Sections 351 and/or 354, 361 and 368 of the Code. Each party hereto will file their respective Tax Returns in accordance with such treatment and will take no action or position which is inconsistent with such treatment unless otherwise required by Law.
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