Common use of For U Clause in Contracts

For U. S. federal income tax purposes, the parties to this Agreement intend that the Merger will qualify as a “reorganization” within the meaning of Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and this Agreement will constitute a “plan of reorganization” within the meaning of United States Treasury Regulations Sections 1.368-2(g) and 1.368-3(a) for purposes of Sections 354, 361 and 368 of the Code.

For U. S. federal income tax purposes, the parties to this Agreement Parties (as defined below) intend that for the Merger will (as defined below) provided for herein to qualify as a “reorganization” within under the meaning provisions of Section 368(a) of the Internal Revenue Code of 1986, (as amended (the “Code”defined below), and this Agreement will constitute is intended to be and is adopted as a “plan of reorganization” within the meaning of United States Treasury Regulations Sections 1.368-2(g) and 1.368-3(a) for purposes of Sections 354, 361 361, and 368 of the CodeCode and within the meaning of Treasury Regulation Section 1.368-2(g).

For U. S. federal income tax Tax purposes (and, where applicable, state and local income Tax purposes), the parties to this Agreement Parties intend that (i) the Parent Merger will qualify as a “reorganization” within the meaning of Section 368(a) of the Internal Revenue Code Code, (ii) the Mergers, taken together, qualify as an exchange within the meaning of 1986Section 351 of the Code, and (iii) this Agreement be, and is hereby adopted, as amended (the “Code”), and this Agreement will constitute a “plan of reorganization” within the meaning of United States Treasury Regulations Sections 1.368-2(g) and 1.368-3(a) for purposes of Sections 354, 361 361, and 368 of the CodeCode and the Treasury Regulations promulgated thereunder.

For U. S. federal income tax Tax purposes, the parties to this Agreement intend it is intended that (i) the Merger will qualify as a “reorganization” within the meaning of Section 368(a) of the Internal Revenue Code of 1986, as amended and (the “Code”)ii) this Agreement be, and this Agreement will constitute it is hereby adopted as a “plan of reorganization” within the meaning of United States Treasury Regulations Sections 1.368-2(g) and 1.368-3(a) for purposes of Sections 354, 361 and 368 of the Code).

For U. S. federal income tax purposes, the parties to this Agreement intend purposes it is intended that the Merger will qualify as a “reorganization” reorganization under Section 368(a) of the Code and that this Agreement shall constitute, and is hereby adopted as, a plan of reorganization within the meaning of Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and this Agreement will constitute a “plan of reorganization” within the meaning of United States Treasury Regulations Sections 1.368-2(g) and 1.368-3(a) for purposes of Sections 354, 361 and 368 354 of the Code.

For U. S. federal income tax purposes, the parties to this Agreement hereto intend that the Merger will qualify as a “reorganization” reorganization within the meaning of Section 368(a) of the Internal Revenue Code and the Company’s Board of 1986, as amended (Directors and the “Code”), Boards of Directors of Parent and Merger Sub have approved this Agreement will and intend that it constitute a “plan of reorganization” reorganization within the meaning of United States Treasury Regulations Sections Regulation Section 1.368-2(g) and 1.368-3(a) for purposes of Sections 354, 361 and 368 of the Code.); and