Tax Effect. The parties intend that the Merger shall qualify as a tax-free reorganization under Section 368(a) of the Code.
Appears in 4 contracts
Samples: Agreement and Plan of Merger (Liberty Media Corp /De/), Agreement and Plan of Merger (Gemstar Tv Guide International Inc), Agreement and Plan of Merger (Sky Global Networks Inc)
Tax Effect. The parties intend that each of the Merger Mergers shall qualify as a tax-free reorganization under within the meaning of Section 368(a) of the CodeCode and that this Agreement shall be and hereby is adopted by each of the parties as a plan of reorganization for purposes of Section 368 of the Code and the Treasury Regulations (as defined in Section 7.01 below) thereunder.
Appears in 3 contracts
Samples: Agreement and Plan of Merger (Liberty Media Corp /De/), Agreement and Plan of Merger (Liberty Media Corp /De/), Agreement and Plan of Merger (Idt Corp)
Tax Effect. The parties intend that each of the Merger Mergers shall qualify as a tax-free reorganization under within the meaning of Section 368(a) of the CodeCode and that this Agreement shall be and hereby is adopted as a plan of reorganization for purposes of Section 368 of the Code and the Treasury Regulations (as defined in Section 7.01) thereunder.
Appears in 1 contract
Samples: Agreement and Plan of Merger (Liberty Media Corp /De/)
