Tax-Free Reorganization. The parties intend that the transaction under this Agreement qualify as a tax free reorganization under Section 368 (a)(1)(B) of the Internal Revenue Code of 1986, as amended.
Appears in 8 contracts
Samples: Securities Purchase Agreement (Viper Networks Inc), Securities Merger Agreement (Viper Networks Inc), Securities Purchase Agreement (Viper Networks Inc)
Tax-Free Reorganization. The parties intend that the transaction under this Agreement qualify as a tax tax-free reorganization under Section 368 (a)(1)(B368(a)(1)(B) of the Internal Revenue Code of 1986, as amended.
Appears in 6 contracts
Samples: Securities Purchase Agreement (Gl Energy & Exploration Inc), Securities Purchase Agreement (Advanced Plant Pharmaceuticals Inc), Securities Purchase Agreement (Tradequest International Inc)
Tax-Free Reorganization. The parties intend that the transaction under this Agreement qualify as a tax tax-free reorganization under Section 368 (a)(1)(B) of the Internal Revenue Code of 1986, as amended.
Appears in 4 contracts
Samples: Asset Purchase Agreement (GBT Technologies Inc.), Asset Purchase Agreement (Trend Innovations Holding Inc.), Stock Purchase Agreement and Plan of Reorganization (Tecscan International Inc)
Tax-Free Reorganization. The parties intend that the transaction under this Agreement qualify as a tax tax-free reorganization under Section Sections 368 (a)(1)(B) and 354 of the Internal Revenue Code of 1986, as amended.
Appears in 4 contracts
Samples: Stock Purchase Agreement (Bluefire Ethanol Fuels Inc), Stock Purchase Agreement (Advanced Growing Systems, Inc.), Stock Purchase Agreement and Plan of Reorganization (National Automation Services Inc)
Tax-Free Reorganization. The parties intend that the transaction ----------------------- under this Agreement qualify as a tax free reorganization under Section 368 (a)(1)(B) of the Internal Revenue Code of 1986, as amended.
Appears in 3 contracts
Samples: Securities Purchase Agreement (G P Properties Inc), Securities Purchase Agreement (Noble Onie Inc), Securities Purchase Agreement (Noble Onie Inc)
Tax-Free Reorganization. The parties intend that the transaction under this Agreement qualify as a tax free reorganization under Section Sections 351 and 368 (a)(1)(B) of the Internal Revenue Code of 1986, as amended.
Appears in 2 contracts
Samples: Securities Purchase Agreement (China Hotel Holdings Inc), Securities Purchase Agreement and Plan of Reorganization (Prologue)
Tax-Free Reorganization. The parties intend that This Agreement and the transaction under this Agreement qualify transactions contemplated herein qualify, in all respects, as a tax free reorganization under pursuant to Code Section 368 (a)(1)(B) of the Internal Revenue Code of 1986, as amended368(a)(2)(D).
Appears in 2 contracts
Samples: Agreement and Plan of Merger (Bristol Retail Solutions Inc), Agreement and Plan of Merger (Bristol Technology Systems Inc)
Tax-Free Reorganization. The parties intend that the transaction ----------------------- under this Agreement qualify as a tax free reorganization under Section 368 (a)(1)(B368(a)(1)(B) of the Internal Revenue Code of 1986, as amended.
Appears in 2 contracts
Samples: Securities Purchase Agreement and Plan of Reorganization (Noble Onie Inc), Securities Purchase Agreement and Plan of Reorganization (Noble Onie Inc)
Tax-Free Reorganization. The It is the express intent of the parties intend to this agreement that the transaction under described in this Agreement qualify is intended as a tax free exchange D reorganization as under Section 368 368(a) (a)(1)(B1) (B) of the Internal Revenue Code of 1986, as amended.
Appears in 1 contract
Samples: Stock Exchange Agreement (Proactive Technologies Inc)
Tax-Free Reorganization. (a) The parties intend that the transaction under to adopt this Agreement qualify as a tax free plan of reorganization under Section and to consummate the Merger in accordance with the provisions of Sections 368 (a)(1)(Ba)(1)(A) and 368(a)(2)(D) of the Internal Revenue Code of 1986, as amendedamended (the "Code").
Appears in 1 contract
Tax-Free Reorganization. The parties intend that the transaction under this Agreement qualify Transaction shall be structured as a tax tax-free reorganization under Section 368 (a)(1)(B) of the Internal Revenue Code of 1986, as amendedamended (except the parties acknowledge that individuals will be taxed to the extent that they receive cash), and the parties shall agree to take all reasonable efforts to effect the Transaction as a tax-free reorganization.
Appears in 1 contract
Samples: South Financial Group Inc
Tax-Free Reorganization. The parties intend that the transaction under transactions pursuant to this Agreement qualify qualify, to the maximum extent possible within the terms hereof, as a tax tax-free reorganization under Section 368 (a)(1)(B368(a) of the Internal Revenue Code of 1986, as amendedamended (the “Code”), and the parties shall report these transactions and otherwise conduct their affairs so as to give effect to such intention.
Appears in 1 contract
Samples: Agreement and Plan of Merger (Us Dry Cleaning Corp)
Tax-Free Reorganization. The parties intend that the transaction under this Agreement qualify as a tax free reorganization under Section 368 (a)(1)(B368(a)(1)(B) of the Internal Revenue Code of 1986, as amended.
Appears in 1 contract
Samples: Securities Purchase Agreement (Newcom International Inc)
Tax-Free Reorganization. The parties intend that the transaction under this Agreement shall qualify as a tax tax-free reorganization under Section 368 (a)(1)(B) of the Internal Revenue Code of 1986, as amended.
Appears in 1 contract
Tax-Free Reorganization. The parties to this Agreement intend that ----------------------- the transaction under contemplated by this Agreement qualify shall be treated as a tax tax-free reorganization under Section 368 (a)(1)(B368(a)(1)(A) and Section 368(a)(2)(D) of the Internal Revenue Code of 1986Code, as amendedand the Treasury Regulations promulgated thereunder.
Appears in 1 contract
Samples: Agreement and Plan of Merger (Physician Health Corp)
Tax-Free Reorganization. The parties intend that the transaction under this Agreement Plan qualify as a tax tax-free reorganization under Section 368 (a)(1)(B368(a)(1)(G) of the Internal Revenue Code of 1986, as amended.
Appears in 1 contract
Samples: Plan of Share Exchange and Reorganization (Terra Media, Ltd.)
Tax-Free Reorganization. The To the extent the transactions subject to ----------------------- this Agreement so qualifies, the parties intend that the transaction under to adopt this Agreement qualify as a tax tax-free reorganization under Section 368 (a)(1)(B) of the Internal Revenue Code of 1986, as amended.
Appears in 1 contract
