Tax Treatment of the Distribution. HHH shall have received an opinion of Xxxxxx & Xxxxxxx LLP regarding the qualification of the Distribution as a distribution under Section 355 of the Code, in form and substance satisfactory to HHH in its sole and absolute discretion.
Appears in 3 contracts
Samples: Separation and Distribution Agreement (Seaport Entertainment Group Inc.), Separation and Distribution Agreement (Seaport Entertainment Group Inc.), Separation and Distribution Agreement (Seaport Entertainment Group Inc.)
Tax Treatment of the Distribution. HHH shall have received an opinion of Xxxxxx Lxxxxx & Xxxxxxx Wxxxxxx LLP regarding the qualification of the Distribution as a distribution under Section 355 of the Code, in form and substance satisfactory to HHH in its sole and absolute discretion.
Appears in 1 contract
Samples: Separation and Distribution Agreement (Howard Hughes Holdings Inc.)
