Common use of Tax Treatment of Transaction Clause in Contracts

Tax Treatment of Transaction. The parties intend that the Target Company Membership Interest exchanged for Holdings Equity pursuant to the Merger are tax-deferred contributions of capital by the Target Company Members in exchange for stock in Holdings under Section 351 of the Code. The Promissory Note Principal Amount is to be treated for income tax purposes as a sale of Target Company Membership Interest by the Target Company Members to Holdings. The parties agree to report the transactions consistent with the treatment described in this Section 6.11 for all Tax purposes.

Tax Treatment of Transaction. The parties intend that the Target Company Membership Interest Shares exchanged for Holdings Equity pursuant to the Merger are tax-deferred contributions of capital by the Target Company Members Stockholders in exchange for stock in Holdings under Section 351 of the Code. The Promissory Note Principal Amount is to be treated for income tax purposes as a sale of Target Company Membership Interest by the Target Company Members to Holdings. The parties agree to report the transactions consistent with the treatment described in this Section 6.11 for all Tax purposes.

Tax Treatment of Transaction. The parties intend that the Target Company Membership Interest exchanged for Holdings Equity pursuant to the Merger are tax-deferred contributions of capital by the Target Company Members in exchange for stock in Holdings under Section 351 of the Code. The Promissory Note Principal Amount is to be treated for income tax purposes as a sale of Target Company Membership Interest by the Target Company Members to Holdings. The parties agree to report the transactions consistent with the treatment described in this Section 6.11 for all Tax purposes.

Tax Treatment of Transaction. The parties intend that the Target Company Membership Interest Common Stock exchanged for Holdings Equity pursuant to the Merger are tax-deferred contributions of capital by the Target Company Members Stockholders in exchange for stock in Holdings under Section 351 of the Code. The Promissory Note Principal Amount is to be treated for income tax purposes as a sale of Target Company Membership Interest Common Stock by the Target Company Members Stockholders to Holdings. The parties agree to report the transactions consistent with the treatment described in this Section 6.11 for all Tax purposes.