Common use of Intention of the Parties — Tax Treatment Clause in Contracts

Intention of the Parties — Tax Treatment. The parties intend the Transaction to qualify, for federal income tax purposes, as a tax-free reorganization under IRC Section 368(a), and the parties hereto hereby adopt this Agreement as a plan of reorganization within the meaning of Sections 1.368-2(g) and 1.368-3(a) of the United States Treasury Regulations.

Intention of the Parties — Tax Treatment. The parties intend the Transaction to qualify, for federal income tax purposes, as a tax-free reorganization under IRC Section 368(a), and the parties hereto hereby adopt this Agreement as a plan of reorganization within the meaning of [Sections 1.368-2(g) and 1.368-3(a) )] of the United States Treasury Regulations.

Intention of the Parties — Tax Treatment. The parties intend for the Transaction Merger to qualify, for federal income tax purposes, as a tax-free reorganization under IRC Section 368(a), and the parties hereto hereby adopt this Agreement as a plan of reorganization within the meaning of Sections 1.368-2(g) and as required under 1.368-3(a) of the United States Treasury Regulations.

Intention of the Parties — Tax Treatment. The parties intend that the Transaction to Merger shall qualify, for federal income tax purposes, as a tax-free reorganization under IRC Section 368(a), and the parties hereto hereby adopt that this Agreement as a shall constitute the “plan of reorganization within the meaning of Sections 1.368-2(g) and 1.368-3(a) reorganization” of the United States Treasury RegulationsMerger for purposes of IRC Section 368.

Intention of the Parties — Tax Treatment. The parties intend the Transaction Merger to qualify, for federal income tax purposes, as a tax-free reorganization under IRC Section 368(a), and the parties hereto hereby adopt this Agreement as a plan of reorganization within the meaning of Sections 1.368-2(g) and 1.368-3(a) of the United States Treasury RegulationsInternal Revenue Code of 1986, as amended (“IRC”).