Medifax Restructuring. (a) The Corporate Taxpayer shall promptly seek a legal opinion from a qualified firm mutually agreeable to the H&F ITR Entity and the BX ITR Entity regarding the federal income tax consequences of the Medifax Restructuring, such restructuring to be in the form proposed by the BX ITR Entity and mutually agreeable to the H&F ITR Entity. If such opinion is at least “more likely than not” that the Medifax Restructuring would have the intended federal income tax consequences (“Medifax Opinion”), the Corporate Taxpayer shall proceed to effectuate the Medifax Restructuring.
Appears in 14 contracts
Samples: Tax Receivable Agreement, Tax Receivable Agreement (PF2 SpinCo, Inc.), Tax Receivable Agreement (PF2 SpinCo, Inc.)
