Xxxxxx Xxxxxx Tax Characterization. The parties hereto recognize and intend that, for United States federal, state and local income, franchise and similar tax purposes, the Trust will be disregarded as an entity separate from Acquiror pursuant to Treas. Reg. 301.7701-3(b), and no party shall take any position on any tax return or otherwise that is inconsistent with such treatment.
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Samples: Voting and Exchange Trust Agreement (Surge Global Energy, Inc.), Stock Purchase Agreement (Surge Global Energy, Inc.)
Xxxxxx Xxxxxx Tax Characterization. The parties hereto recognize and intend that, for United States federal, state and local income, franchise and similar tax purposes, the Trust will be disregarded as an entity separate from Acquiror Acquirer pursuant to Treas. Reg. 301.7701-3(b), and no party shall take any position on any tax return or otherwise that is inconsistent with such treatment.
Appears in 1 contract
Samples: Voting and Exchange Trust Agreement (Canwest Petroleum Corp)
Xxxxxx Xxxxxx Tax Characterization. The parties hereto recognize and intend that, for United States federal, state and local income, franchise and similar tax purposes, the Trust will be disregarded as an entity separate from Acquiror FCE pursuant to Treas. Reg. 301.7701-3(b), and no party shall take any position on any tax return or otherwise that is inconsistent with such treatment.
Appears in 1 contract
