Section 351 Statements Clause Samples

Section 351 Statements. (a) Each Contributor shall file a “transferor’s statement” under Treasury Regulations § 1.351-3(a) with the Internal Revenue Service with the Contributor’s federal income tax return, for its taxable year in which the Closing occurred. The statement shall be in substantially the form attached hereto as Exhibit B and the Contributor shall furnish to the Company a copy of the statement as and when filed with such return.