For U. S. federal income tax purposes, the Parties (as defined below) intend for the Merger (as defined below) provided for herein to qualify as a “reorganization” under the provisions of Section 368(a) of the Code (as defined below), and this Agreement is intended to be and is adopted as a “plan of reorganization” for purposes of Sections 354, 361, and 368 of the Code and within the meaning of Treasury Regulation Section 1.368-2(g).
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Samples: Agreement and Plan of Merger (Reliant Bancorp, Inc.), Agreement and Plan of Merger (United Community Banks Inc)
For U. S. federal income tax purposes, the Parties (as defined below) parties to this Agreement intend for that the Merger (as defined below) provided for herein to will qualify as a “reorganization” under within the provisions meaning of Section 368(a) of the Internal Revenue Code of 1986, as amended (as defined belowthe “Code”), and this Agreement is intended to be and is adopted as 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 Code and within the meaning of Treasury Regulation Section 1.368-2(g)Code.
Appears in 2 contracts
Samples: Agreement of Merger (HilleVax, Inc.), Agreement of Merger (Phathom Pharmaceuticals, Inc.)
For U. S. federal income tax purposes, the Parties (as defined below) intend for it is intended that the Merger (as defined below) provided for herein to shall qualify as a “reorganization” under reorganization within the provisions meaning of Section 368(a) of the Internal Revenue Code of 1986, as amended (as defined belowthe "Code"), and this Agreement is intended to be constitutes and hereby is adopted as a “plan of reorganization” for purposes of Sections 354, 361, and 368 of the Code and within the meaning of Treasury Regulation Section 1.368-2(g).
Appears in 1 contract
Samples: Agreement and Plan of Merger Agreement and Plan of Merger (M-Systems Flash Disk Pioneers LTD)
For U. S. federal income tax Tax purposes, the Parties it is intended that (as defined belowi) intend for the Merger (as defined below) provided for herein to will qualify as a “reorganization” under within the provisions meaning of Section 368(a) of the Code and (as defined below)ii) this Agreement be, and this Agreement it is intended to be and is hereby adopted as a “plan of reorganization” for purposes of Sections 354, 361, and 368 of the Code and within the meaning of Treasury Regulation Section Regulations Sections 1.368-2(g) and 1.368-3(a).
Appears in 1 contract
