Common use of Treatment as Reorganization Clause in Contracts

Treatment as Reorganization. It is intended by the Parties that the transactions contemplated hereby and by the Other Agreements shall qualify as a “reorganization” within the meaning of section 368(a)(1)(B) of the Code. Notwithstanding the foregoing, no Party makes any representations as to the tax consequences of the transactions contemplated by this Agreement or the Other Agreements.

Treatment as Reorganization. It is intended by the Parties parties hereto that the transactions contemplated hereby and by the Other Agreements shall qualify as a “reorganization” within the meaning of section 368(a)(1)(BSection 368(a)(1)(C) of the Code. Notwithstanding the foregoing, no Party party to this Agreement makes any representations as to the tax consequences of the transactions contemplated by this Agreement or the Other AgreementsAgreement.