0001193125-18-246042 Sample Contracts

TAX MATTERS AGREEMENT
Tax Matters Agreement • August 10th, 2018 • Linn Energy, Inc. • Crude petroleum & natural gas • Texas

This Tax Matters Agreement (the “Agreement”) is entered into as of August 7, 2018 by and among Linn Energy, Inc., a Delaware corporation (“Linn”), Riviera Resources, Inc., a Delaware corporation formed as a result of the reorganization of the predecessor Linn Energy, Inc. in July 2018 (“SpinCo”), and the SpinCo Subsidiaries (as defined below, and collectively with SpinCo, the “SpinCo Parties,” and the SpinCo Parties collectively with Linn, the “Parties”).

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SEPARATION AND DISTRIBUTION AGREEMENT by and between LINN ENERGY, INC. and RIVIERA RESOURCES, INC. Dated as of August 7, 2018
Separation and Distribution Agreement • August 10th, 2018 • Linn Energy, Inc. • Crude petroleum & natural gas • Delaware

SEPARATION AND DISTRIBUTION AGREEMENT (this “Agreement”), dated as of August 7, 2018, by and between Riviera Resources, Inc., a Delaware corporation (“SpinCo”), and Linn Energy, Inc., a Delaware corporation (“Linn”). SpinCo, on the one hand, and Linn, on the other hand, are sometimes referred to herein collectively as the “Parties” and individually as a “Party.” Capitalized terms shall have the meanings set forth in Section 1.1.

TRANSITION SERVICES AGREEMENT by and between LINN ENERGY, INC. AND RIVIERA RESOURCES, INC. Dated as of August 7, 2018
Transition Services Agreement • August 10th, 2018 • Linn Energy, Inc. • Crude petroleum & natural gas • Delaware

THIS TRANSITION SERVICES AGREEMENT (this “Agreement”), effective as of August 7, 2018 (the “Effective Date”), is hereby made by and between Riviera Resources, Inc., a Delaware corporation (“Service Provider”), and Linn Energy, Inc., a Delaware corporation (“Service Recipient”). Service Provider and Service Recipient are each referred to herein as a “Party” and collectively, as the “Parties.”

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