Treatment of Payments. The parties hereto shall treat any payments made pursuant to the terms of this Agreement as a capital transaction for all tax purposes, except to the extent such payments represent interest paid pursuant to Section 2.6.
Appears in 4 contracts
Samples: Tax Disaffiliation Agreement (Waddell & Reed Financial Inc), Tax Disaffiliation Agreement (Chemfirst Inc), Tax Disaffiliation Agreement (Waddell & Reed Financial Inc)
Treatment of Payments. The parties hereto shall treat any payments made pursuant to the terms of this Agreement as a capital transaction for all tax Tax purposes, except to the extent such payments represent interest paid pursuant to Section 2.6.
Appears in 2 contracts
Samples: Tax Disaffiliation Agreement (Octel Corp), Tax Disaffiliation Agreement (Octel Corp)
Treatment of Payments. The parties hereto shall treat any payments made pursuant to the terms of this Agreement as a capital transaction occurring prior to the Distribution Date for all tax Tax purposes, except to the extent such payments represent interest paid pursuant to Section 2.62.7.
Appears in 2 contracts
Samples: Tax Disaffiliation Agreement (Wca Waste Corp), Tax Disaffiliation Agreement (Wca Waste Corp)
Treatment of Payments. The parties hereto shall treat any payments made pursuant to the terms of this Agreement as a capital transaction for all tax purposes, except to the extent such payments represent interest paid pursuant to Section 2.6.
Appears in 2 contracts
Samples: Tax Disaffiliation Agreement (Aegon Nv /Ia/), Tax Disaffiliation Agreement (Providian Bancorp Inc)
Treatment of Payments. The parties hereto shall treat any payments made pursuant to the terms of this Agreement as a capital transaction occurring prior to the Merger Date for all tax Tax purposes, except to the extent such payments represent interest paid pursuant to Section 2.62.7.
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Treatment of Payments. The parties hereto shall treat any --------------------- payments made pursuant to the terms of this Agreement as a capital transaction for all tax Tax purposes, except to the extent such payments represent interest paid pursuant to Section 2.6.
Appears in 1 contract
Samples: Tax Disaffiliation Agreement (Strategix Solutions Inc)
Treatment of Payments. The parties hereto shall treat any payments made pursuant to the terms of this Agreement as a capital transaction for all tax purposes, except to the extent such payments represent interest paid pursuant to Section 2.62.7.
Appears in 1 contract
Treatment of Payments. The parties hereto shall treat any payments made pursuant to the terms of this Agreement as a capital transaction for all tax purposes, except to the extent such payments represent interest paid pursuant to Section 2.6.
Appears in 1 contract
