Tax Treatment of the Distribution. Illumina shall have received a private letter ruling from the Internal Revenue Service and the written opinion of Xxxxxxx, Swaine & Xxxxx LLP, each of which shall remain in full force and effect, that, subject to the limitations specified therein and the accuracy of and compliance with certain representations, the Distribution will qualify for non-recognition of gain and loss under Sections 355 and 368 of the Code.
Appears in 3 contracts
Samples: Separation and Distribution Agreement (Illumina, Inc.), Separation and Distribution Agreement (Grail, LLC), Separation and Distribution Agreement (Grail, LLC)
Tax Treatment of the Distribution. Illumina shall have received a private letter ruling from the Internal Revenue Service and the written opinion of XxxxxxxCravath, Swaine & Xxxxx Moore LLP, each of which shall remain in full force and effect, that, subject to the limitations specified therein and the accuracy of and compliance with certain representations, the Distribution will qualify for non-recognition of gain and loss under Sections 355 and 368 of the Code.
Appears in 1 contract
Samples: Separation and Distribution Agreement (GRAIL, Inc.)
