No Contrary Knowledge. Each of OPC and CRC represents that, as of the date of this Agreement, it knows of no fact (after due inquiry) that may cause the Tax treatment of the Internal Spin-Off or the External Spin-Off to be other than that contemplated in the Separation and Distribution Agreement and the Tax Opinion.
Appears in 3 contracts
Sources: Tax Sharing Agreement (California Resources Corp), Tax Sharing Agreement (Occidental Petroleum Corp /De/), Tax Sharing Agreement (California Resources Corp)