U.S. Federal Income Tax Treatment. The exchange of Warrants for shares of Class A Common Stock pursuant to the Exchange Offer is intended to qualify as a reorganization pursuant to Section 368 of the Internal Revenue Code of 1986, as amended, and the parties shall not take any position inconsistent therewith unless otherwise required by applicable law.
Appears in 5 contracts
Samples: Tender and Support Agreement (OPAL Fuels Inc.), Tender and Support Agreement (Ranpak Holdings Corp.), Tender and Support Agreement (Ranpak Holdings Corp.)
U.S. Federal Income Tax Treatment. The exchange of Warrants for shares of Class A Common Stock Ordinary Shares pursuant to the Exchange Offer is intended to qualify as a reorganization pursuant to Section 368 of the Internal Revenue Code of 1986, as amended, and the parties shall not take any position inconsistent therewith unless otherwise required by applicable law.
Appears in 3 contracts
Samples: Tender and Support Agreement (Allego N.V.), Private Placement Warrant Tender and Support Agreement (TH International LTD), Public Warrants Tender and Support Agreement (TH International LTD)
U.S. Federal Income Tax Treatment. The exchange of Private Warrants for shares of Class A A-1 Common Stock pursuant to the Exchange Offer is intended to qualify as a reorganization pursuant to Section 368 of the Internal Revenue Code of 1986, as amended, and the parties shall not take any position inconsistent therewith unless otherwise required by applicable law.
Appears in 2 contracts
Samples: Tender and Exchange Agreement (Accel Entertainment, Inc.), Tender and Exchange Agreement (Accel Entertainment, Inc.)
U.S. Federal Income Tax Treatment. The exchange of Warrants for shares of Class A Common Stock pursuant to the Exchange Offer is intended to qualify as a reorganization pursuant to Section 368 of the Internal Revenue Code of 1986, as amended, and the parties shall not take any position inconsistent therewith unless otherwise required by applicable law.
Appears in 2 contracts
Samples: Tender and Support Agreement (Granite Ridge Resources, Inc.), Tender and Support Agreement (Granite Ridge Resources, Inc.)
U.S. Federal Income Tax Treatment. The exchange of the Warrants for shares of Class A Common Stock of the Company pursuant to the Exchange Offer is intended to qualify as a reorganization pursuant to Section 368 368(a)(1)(E) of the Internal Revenue Code of 1986, as amended, and the parties shall not take any position inconsistent therewith unless otherwise required by applicable law.
Appears in 2 contracts
Samples: Tender and Support Agreement (Hagerty, Inc.), Tender and Support Agreement (Hagerty, Inc.)
U.S. Federal Income Tax Treatment. The exchange of Private Placement Warrants for shares of Class A Common Stock pursuant to the Exchange Offer is intended to qualify as a reorganization pursuant to Section 368 of the Internal Revenue Code of 1986, as amended, and the parties shall not take any position inconsistent therewith unless otherwise required by applicable law.
Appears in 1 contract
Samples: Tender and Support Agreement (Atlas Technical Consultants, Inc.)
U.S. Federal Income Tax Treatment. The exchange of Warrants for shares of Class A Common Stock pursuant to the Exchange Offer is intended to qualify as a reorganization recapitalization pursuant to Section 368 of the Internal Revenue Code of 1986, as amended, and the parties shall not take any position inconsistent therewith unless otherwise required by applicable law.
Appears in 1 contract
U.S. Federal Income Tax Treatment. The exchange of Public Warrants or Private Warrants for ordinary shares of Class A Common Stock the Company pursuant to the Exchange Offer is intended to qualify as a reorganization pursuant to Section 368 of the Internal Revenue Code of 1986, as amended, and the parties shall not take any position inconsistent therewith unless otherwise required by applicable law.
Appears in 1 contract
Samples: Tender and Support Agreement (Playa Hotels & Resorts N.V.)
