Integrated Transaction. At the time of the first closing of the First PIPE, Acquiror intended (i) to complete the additional issuance of Acquiror Shares and/or Acquiror Pre-Funded Warrants contemplated hereunder as soon as practicable following completion of the First PIPE and (ii) that such transaction would, together with the Acquiror Share Issuances and the Transaction, constitute a single integrated transaction qualifying as a tax-deferred contribution under Section 351(a) of the Code.
Appears in 2 contracts
Sources: Securities Contribution Agreement (ZeroStack Corp.), Share Exchange Agreement (ZeroStack Corp.)