Common use of U.S. Tax Matters Clause in Contracts

U.S. Tax Matters. The (i) Arrangement is intended to qualify as a “reorganization” within the meaning of Section 368(a) of the Code, (ii) Agreement and the Plan of Arrangement are intended to constitute a “plan of reorganization” within the meaning of the U.S. Treasury Regulations Section 1.368-2(g), and (iii) Arrangement is intended to qualify for the nonrecognition provisions of Section 897(e) of the Code and Treas. Reg.

U.S. Tax Matters. The (i) Arrangement is intended to qualify as a “reorganization” reorganization within the meaning of Section 368(aSections 368(a)(1)(A) and 368(a)(2)(D) of the Code, (ii) Code and this Plan of Agreement and the Plan of Arrangement Agreement are intended to constitute be a “plan of reorganization” within the meaning of the U.S. Treasury Regulations promulgated under Section 1.368-2(g), and (iii) Arrangement is intended to qualify for the nonrecognition provisions of Section 897(e) 368 of the Code for purposes of Sections 354 and Treas. Reg361 of the Code.

U.S. Tax Matters. The (i) Arrangement is intended to qualify as a “reorganization” reorganization within the meaning of Section 368(aSections 368(a)(1)(B) of the Code, (ii) U.S Tax Code and this Plan of Agreement and the Plan of Arrangement Agreement are intended to constitute be a “plan of reorganization” within the meaning of the U.S. Treasury Regulations promulgated under Section 1.368-2(g), and (iii) Arrangement is intended to qualify for the nonrecognition provisions of Section 897(e) 368 of the U.S. Tax Code for purposes of Sections 354 and Treas. Reg361 of the U.S. Tax Code.

U.S. Tax Matters. The (i) Arrangement is intended to qualify as a “reorganization” reorganization within the meaning of Section 368(aSections 368(a)(1)(B) of the Code, (ii) Code and this Plan of Agreement and the Plan of Arrangement Agreement are intended to constitute be a “"plan of reorganization” " within the meaning of the U.S. Treasury Regulations promulgated under Section 1.368-2(g), and (iii) Arrangement is intended to qualify for the nonrecognition provisions of Section 897(e) 368 of the Code for purposes of Sections 354 and Treas. Reg361 of the Code.

U.S. Tax Matters. The (i) Arrangement is intended to qualify as a “reorganization” reorganization within the meaning of Section 368(aSections 368(a)(1)(B) of the Code, (ii) Code and this Plan of Agreement and the Plan of Arrangement Agreement are intended to constitute be a “plan of reorganization” within the meaning of the U.S. Treasury Regulations promulgated under Section 1.368-2(g), and (iii) Arrangement is intended to qualify for the nonrecognition provisions of Section 897(e) 368 of the Code for purposes of Sections 354 and Treas. Reg361 of the Code.