Intended Income Tax Treatment definition

Intended Income Tax Treatment has the meaning specified in Section 8.03(a)(i).
Intended Income Tax Treatment has the meaning specified in the Recitals hereto.
Intended Income Tax Treatment has the meaning specified in Section 10.04(b).

Examples of Intended Income Tax Treatment in a sentence

  • Each of the Parties agrees to promptly notify all other Parties of any challenge to the Intended Income Tax Treatment by any Governmental Authority.

  • The Parties will prepare and file all Tax Returns consistent with the Intended Income Tax Treatment and will not take any inconsistent position on any Tax Return or during the course of any audit, litigation or other proceeding with respect to Taxes, except as otherwise required by a determination within the meaning of Section 1313(a) of the Code.

  • Each of the Parties agrees to promptly notify all other Parties in writing of any challenge to the Intended Income Tax Treatment by any Governmental Authority (with such notice including a copy of any such challenge).

  • Intended Income Tax Treatment of Certain Aspects of the Separation Transactions 9 Section 2.02.

  • Each of the Parties agrees to reasonably cooperate with each other and their respective counsel to document and provide factual support for the Intended Income Tax Treatment, including by reasonably cooperating to provide customary factual support letters.


More Definitions of Intended Income Tax Treatment

Intended Income Tax Treatment has the meaning specified in Section 2.07.
Intended Income Tax Treatment. Section 8.04(a)
Intended Income Tax Treatment has the meaning as set forth in Section VII.4(a).
Intended Income Tax Treatment is defined in Section 12.10.
Intended Income Tax Treatment is defined in Section 6.09(f).
Intended Income Tax Treatment means, for U.S. federal income tax purposes (and for purposes of any applicable state or local tax Legal Requirements that follow the U.S. federal income tax treatment), the intention that (i) the Mergers (as defined in the A&R Merger Agreement) constitute an integrated transaction that qualifies as a “reorganization” within the meaning of Section 368(a) of the Code (and any comparable provision of state or local tax Legal Requirements) to which each of Parent and the Company are parties under Section 368(b) of the Code and (ii) Purchaser’s exchange of the Shares for Parent Series X Shares pursuant to the Mergers will be treated as a tax-free exchange pursuant to Section 354 of the Code.
Intended Income Tax Treatment means, for U.S. federal income tax purposes, the intent of the parties to the Merger Agreement that (i) the First Merger and the Second Merger, taken together, constitute an integrated transaction that qualifies as a “reorganization” within the meaning of Section 368(a) of the Code and the regulations promulgated thereunder to which DFP and TOI are parties under Section 368(b) of the Code, and (ii) the Merger Agreement be, adopted as a “plan of reorganizationfor purposes of Section 368 of the Code and Section 1.368-2(g) of the regulations promulgated thereunder.