No Contrary Knowledge. Each of UWWH, IP and Spinco represents and warrants, as of the date hereof and as of the Effective Time, that it knows of no fact (after due inquiry) that would prevent the Tax treatment of the Controlled 1 Contribution, the First Internal Distribution, the Second Internal Distribution, the Third Internal Distribution, the Spinco Contribution, the Distribution or any other Covered Transaction from being consistent with the Tax-Free Status of the Transactions.
Appears in 3 contracts
Sources: Tax Matters Agreement (Xpedx Holding Co), Tax Matters Agreement, Tax Matters Agreement