Tax and Accounting Consequences. For federal income tax purposes, the Merger is intended to constitute a reorganization within the meaning of Section 368 of the Internal Revenue Code, and the Parties shall report the transactions contemplated herein consistent with such intent and shall take no position inconsistent therewith. The Parties to this Agreement hereby adopt this Agreement as a “plan of reorganization” within the meaning of Sections 1.368-2(g) and 1.368-3(a) of the United States Treasury Regulations.
Appears in 9 contracts
Samples: Agreement and Plan of Merger (Pinecrest Investment Group Inc), Agreement and Plan of Merger (Strata Capital Corp), Agreement and Plan of Merger (Eyes on the Go, Inc.)
Tax and Accounting Consequences. For federal income tax purposes, it is intended by the parties hereto that the transaction effected through the Merger is intended to shall constitute a reorganization within the meaning of Section 368 of the Internal Revenue Code, and the Parties shall report the transactions contemplated herein consistent with such intent and shall take no position inconsistent therewith. The Parties to this Agreement parties hereto hereby adopt this Agreement as a “"plan of reorganization” " within the meaning of Sections 1.368-2(g) and 1.368-3(a) of the United States Treasury Regulations. For accounting purposes, it is intended by the parties hereto that the Merger shall be accounted for as a "pooling."
Appears in 1 contract
Samples: Agreement and Plan of Merger (Netgain Development Inc)
