Reportable Transactions. Neither the Company nor any of its Subsidiaries has entered into any transaction that constitutes (i) a “reportable transaction” within the meaning of Treasury Regulation § 1.6011-4(b), (ii) a “confidential tax shelter” within the meaning of Treasury Regulation § 301.6111-2(a)(2) or a “potentially abusive tax shelter” within the meaning of Treasury Regulation § 301.6112-1(b).
Appears in 2 contracts
Sources: Merger Agreement (Harber Lacy J), Merger Agreement (Timco Aviation Services Inc)
Reportable Transactions. Neither the The Company nor any of its Subsidiaries has not entered into any transaction that constitutes (i) a “reportable transaction” within the meaning of Treasury Regulation § 1.6011-4(b), (ii) a “confidential tax shelter” within the meaning of Treasury Regulation § 301.6111-2(a)(2) or (iii) a “potentially abusive tax shelter” within the meaning of Treasury Regulation § 301.6112-1(b).
Appears in 1 contract
Sources: Merger Agreement (UpSnap, Inc.)
Reportable Transactions. Neither the Company nor any of its Subsidiaries has entered into any transaction that constitutes (i) a “"reportable transaction” " within the meaning of Treasury Regulation § ss. 1.6011-4(b), (ii) a “"confidential tax shelter” " within the meaning of Treasury Regulation § ss. 301.6111-2(a)(2) or a “"potentially abusive tax shelter” " within the meaning of Treasury Regulation § ss. 301.6112-1(b).
Appears in 1 contract
Sources: Merger Agreement (Owl Creek I Lp)
Reportable Transactions. Neither the Company nor any of its Subsidiaries has entered into any transaction that constitutes (i) a “reportable transaction” within the meaning of Treasury Regulation § 1.6011-4(b), (ii) a “confidential tax shelter” within the meaning of Treasury Regulation § 301.6111-2(a)(2) or (iii) a “potentially abusive tax shelter” within the meaning of Treasury Regulation § 301.6112-1(b).
Appears in 1 contract
Sources: Merger Agreement (Checkers Drive in Restaurants Inc /De)
Reportable Transactions. Neither the Company nor any of its Subsidiaries subsidiaries has entered into any engaged in a reportable transaction that constitutes (i) a “reportable transaction” within the meaning of under Treasury Regulation § Regulations Section 1.6011-4(b), (ii) including a “confidential transaction that is the same as or substantially similar to one of the types of transactions that the IRS has determined to be a tax shelter” within the meaning avoidance transaction and identified by notice, regulation, or other form of published guidance as a listed transaction, as set forth in Treasury Regulation § 301.6111Regulations Section 1.6011-2(a)(2) or a “potentially abusive tax shelter” within the meaning of Treasury Regulation § 301.6112-1(b4(b)(2).
Appears in 1 contract
Sources: Unit Purchase Agreement (Yext, Inc.)