Domestication definition
Examples of Domestication in a sentence
In connection with the Domestication, all of the issued and outstanding SPAC Securities shall be exchanged for or converted into substantially identical securities of SPAC as a Delaware corporation.
For the avoidance of doubt, the Domestication is intended to constitute a “reorganization” within the meaning of Section 368(a)(1)(F) of the Code.
The Parties intend to report and shall report, for federal income tax purposes, and shall not take any position inconsistent with (whether in audits, Tax Returns or otherwise) the treatment of, each of the Merger, the Plutus-Company Distribution and the Domestication, respectively, as a “reorganization” within the meaning of Section 368(a) of the Code unless otherwise required by a Governmental Authority as a result of a “determination” within the meaning of Section 1313(a) of the Code.
None of the Parties shall (and each of the Parties shall cause their respective Subsidiaries not to) take any action, or fail to take any action, that could reasonably be expected to cause the Merger, the Plutus-Company Distribution or the Domestication to fail to qualify, respectively, as a “reorganization” within the meaning of Section 368(a) of the Code.
For federal income tax purposes, (i) the Domestication is intended to constitute a “reorganization” within the meaning of Section 368(a)(1)(F) of the Code and (ii), with respect to the Domestication, the SPAC hereby adopts this Agreement as a “plan of reorganization” within the meaning of Sections 1.368-2(g) and 1.368-3(a) of the United States Treasury Regulations.