Reorganization Treatment. (a) Parent, Merger Sub and the Company intend that, for U.S. federal income tax purposes, (i) the Merger shall qualify as a “reorganization” within the meaning of Section 368(a) of the Code and (ii) this Agreement shall constitute a “plan of reorganization” within the meaning of Treasury Regulation Sections 1.368-2(g) and 1.368-3(a).
Appears in 3 contracts
Samples: Agreement and Plan of Merger (Cheniere Energy Inc), Agreement and Plan of Merger (Cheniere Energy Inc), Agreement and Plan of Merger (Cheniere Energy Partners LP Holdings, LLC)
Reorganization Treatment. (a) Parent, Merger Sub and the Company intend that, It is intended that for U.S. federal income tax purposes, (i) the Merger shall qualify as a “reorganization” within the meaning of Section 368(a) of the Code and (ii) the Treasury Regulations promulgated thereunder, and this Agreement shall constitute is hereby adopted as a “plan of reorganization” within for purposes of Sections 354, 361 and 368 of the meaning of Code and Treasury Regulation Regulations Sections 1.368-2(g) and 1.368-3(a).
Appears in 2 contracts
Samples: Release Agreement (Lawson Products Inc/New/De/), Release Agreement (Lawson Products Inc/New/De/)
Reorganization Treatment. (a) Parent, Merger Sub and the Company intend that, It is intended that for U.S. federal income tax purposes, (i) the Merger shall qualify as a “reorganization” within the meaning of Section 368(a) of the Code Code, and (ii) this Agreement shall constitute is hereby adopted as a “plan of reorganization” within the meaning of Treasury Regulation Regulations Sections 1.368-2(g) and 1.368-3(a).
Appears in 1 contract
Samples: Agreement and Plan of Merger (Nci Building Systems Inc)
