Examples of Internal Reorganization Step Plan in a sentence
The Tax treatment of the Separation Transactions reported on any Tax Return shall be consistent with the treatment thereof in the Tax Opinion and Internal Reorganization Step Plan, taking into account the jurisdiction in which such Tax Returns are filed, unless there is no reasonable basis for such Tax treatment.
The Seller shall not, and shall cause the Company Entities not to, make modifications to or deviate from the Internal Reorganization Step Plan with respect to the Internal Reorganization, in each case, without the Buyer’s prior written consent (not to be unreasonably withheld).
Schedule 2.1(a) Internal Reorganization Step Plan In consideration of the Spin-Off, effective as of the Business Transfer Time, the following steps shall be consummated (and deemed consummated) in the following order: Step 1: Cogint shall contribute to SpinCo all of the outstanding equity interests of the SpinCo Subsidiaries that are directly owned by Cogint.
All of the foregoing documents contemplated by this Section 2.1(b) (including any documents entered into between or among any of the Parties or members of their respective Groups to implement or in furtherance of the Internal Reorganization in accordance with the Internal Reorganization Step Plan prior to the date hereof) shall be referred to collectively herein as the “Transfer Documents.” Confidential Treatment Requested by WK Xxxxxxx Co Pursuant to 17 C.F.R. Section 200.83 (c) Misallocations.