Intended Tax Treatment. The parties intend the Merger to be treated as a reorganization under Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and the rules and regulations thereunder, and intend for this Agreement to constitute a “plan of reorganization” within the meaning of the Code.
Appears in 3 contracts
Samples: Agreement and Plan of Merger (Wachovia Corp New), ____________________________________________________________________________________ Agreement and Plan of Merger (Edwards a G Inc), Agreement and Plan of Merger (Main Street Trust Inc)
Intended Tax Treatment. The parties intend It is intended that the Merger to be treated shall qualify as a reorganization under “reorganization” within the meaning of Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and the rules and regulations thereunderthat this Agreement is intended to be, and intend for this Agreement to constitute is adopted as, a “plan of reorganization” within the meaning for purposes of Sections 354 and 361 of the Code.
Appears in 3 contracts
Samples: Agreement and Plan of Merger (Rock-Tenn CO), Agreement and Plan of Merger (Rock-Tenn CO), Agreement and Plan of Merger (SMURFIT-STONE CONTAINER Corp)
Intended Tax Treatment. The parties intend the Merger to be treated as a reorganization under Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and the rules and regulations thereunder, and intend for this Agreement to constitute a “plan of reorganization” within the meaning of the Code.
Appears in 3 contracts
Samples: Agreement and Plan of Merger (Cullen Frost Bankers Inc), Agreement and Plan of Merger (Summit Bancshares Inc /Tx/), Agreement and Plan of Merger (Cullen Frost Bankers Inc)
Intended Tax Treatment. The parties intend the Merger and the Parent Merger to be treated for federal income tax purposes as a reorganization single integrated transaction that will qualify as a “reorganization” under Section 368(a) of the Internal Revenue Code of 1986, as amended 1986 (the “Code”) (the “Intended Tax Treatment”), and the rules and regulations thereunder, and . The parties intend for that this Agreement to constitute be and hereby is adopted as a “plan of reorganization” within the meaning of Sections 354 and 361 of the Code.
Appears in 2 contracts
Samples: Agreement and Plan of Merger (FCB Financial Holdings, Inc.), Agreement and Plan of Merger (First Midwest Bancorp Inc)
Intended Tax Treatment. The parties intend the Merger and the Parent Merger to be treated for federal income tax purposes as a reorganization under single integrated transaction that will qualify as a “reorganization” within the meaning of Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”) (the “Intended Tax Treatment”), and the rules and regulations thereunder, and . The parties intend for that this Agreement to constitute be and hereby is adopted as a “plan of reorganization” within the meaning for purposes of Sections 354 and 361 of the Code.
Appears in 2 contracts
Samples: Agreement and Plan of Merger, Agreement and Plan of Merger (Byline Bancorp, Inc.)
Intended Tax Treatment. The parties intend It is intended that the Merger to be treated Mergers, taken together, shall qualify as a reorganization under “reorganization” within the meaning of Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and that the rules and regulations thereunder, and intend for this Merger Agreement to constitute constitutes a “plan of reorganization” within the meaning of the CodeTreasury Regulations §§ 1.368-2(g) and 1.368-3(a).
Appears in 2 contracts
Samples: Agreement and Plan of Merger (Midstates Petroleum Company, Inc.), Agreement and Plan of Merger (Amplify Energy Corp)
Intended Tax Treatment. The parties to this Agreement intend that the Merger to be treated as a reorganization under described in Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and the rules and regulations thereunder, and intend for this Agreement to constitute a “plan of reorganization” within the meaning of the Code.
Appears in 2 contracts
Samples: Agreement and Plan of Merger (Vision Bancshares Inc), Agreement and Plan of Merger (Park National Corp /Oh/)
Intended Tax Treatment. The parties intend the Merger to be treated qualify as a reorganization under Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and the rules and regulations thereunder, ) and intend for this Agreement to constitute a “plan of reorganization” within the meaning for purposes of Sections 354 and 361 of the Code.
Appears in 2 contracts
Samples: Agreement and Plan of Merger (S&t Bancorp Inc), Agreement and Plan of Merger (FNB United Corp.)
Intended Tax Treatment. The parties intend It is intended that the Merger to be treated Mergers, taken together, shall qualify as a reorganization under Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and the rules and regulations thereunder, and intend for this Agreement to constitute a “plan of reorganization” within the meaning of Section 368(a) of the Code, and that the Merger Agreement is intended to be a plan of reorganization for purposes of Sections 354 and 361 of the Code and within the meaning of Treasury Regulations Section 1.368-2(g) and 1.368-3(a).
Appears in 2 contracts
Samples: Agreement and Plan of Merger (C&J Energy Services, Inc.), Agreement and Plan of Merger (Keane Group, Inc.)
Intended Tax Treatment. The parties intend the Merger to be treated as a reorganization under Section 368(a) of the Internal Revenue Code of 1986, as amended 1986 and the rules and regulations thereunder (the “Code”), and the rules and regulations thereunder, ) and intend for this Agreement to constitute a “plan of reorganization” within the meaning of the Code.
Appears in 2 contracts
Samples: Agreement and Plan of Merger (Amegy Bancorporation, Inc.), Agreement and Plan of Merger (Zions Bancorporation /Ut/)
Intended Tax Treatment. The parties intend the Merger to be treated as a reorganization under Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), ) and the rules and regulations thereunder, thereunder and intend for this Agreement to constitute a “plan of reorganization” within the meaning of the Code.
Appears in 1 contract
Intended Tax Treatment. The parties intend the Merger to be treated qualify as a reorganization under Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and the rules and regulations thereunder, ) and intend for this Agreement to constitute a “plan of reorganization” within the meaning for purposes of Sections 354 and 361 of the Code.. NOW, THEREFORE, in consideration of the foregoing premises and of the mutual covenants, representations, warranties and agreements contained herein, and intending to be legally bound hereby, the parties agree as follows:
Appears in 1 contract
Samples: Agreement and Plan of Merger (Bank of Granite Corp)
Intended Tax Treatment. The parties intend the Merger to be treated as a reorganization under Section 368(a) of the Internal Revenue Code of 1986, as amended 1986 (the “Code”), and the rules and regulations thereunder, and intend for this Agreement to constitute a “plan of reorganization” within the meaning of the Code.
Appears in 1 contract
Intended Tax Treatment. The parties intend the Merger to be treated as a reorganization under the provisions of Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”)amended, and the rules and regulations thereunder, and intend for this Agreement to constitute a “plan of reorganization” within promulgated thereunder (the meaning of the "Code").
Appears in 1 contract
Samples: Agreement and Plan of Merger (Amsouth Bancorporation)
Intended Tax Treatment. The parties intend the Merger to be treated as a reorganization under Section 368(a) of the Internal Revenue Code of 1986, as amended 1986 (the “"Code”"), and the rules and regulations thereunder, and intend for this Agreement to constitute a “plan of reorganization” within the meaning of the Code.
Appears in 1 contract
Samples: Agreement and Plan of Merger (Cb Bancshares Inc/Hi)
Intended Tax Treatment. The parties intend It is intended that the Merger to be treated will qualify as a reorganization under “reorganization” within the meaning of Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and the rules and regulations thereunderthat this Agreement is intended to be, and intend for this Agreement to constitute is adopted as, a “plan of reorganization” within the meaning for purposes of Sections 354 and 361 of the Code.
Appears in 1 contract
Samples: Agreement and Plan of Merger (American Homes 4 Rent)
Intended Tax Treatment. The parties intend the Merger to be treated as a reorganization under Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”"CODE"), and the rules and regulations thereunder, and intend for this Agreement to constitute a “"plan of reorganization” " within the meaning of the Code.
Appears in 1 contract
Samples: Agreement and Plan of Merger (Golden West Financial Corp /De/)
Intended Tax Treatment. The parties intend It is intended that the Merger to be treated as shall constitute a reorganization under “reorganization” within the meaning of Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and the rules and regulations thereunder, and intend for that this Agreement to shall constitute a “plan of reorganization” within the meaning for purposes of Sections 354 and 361 of the Code.
Appears in 1 contract
Samples: Agreement and Plan of Merger (Digital Cinema Destinations Corp.)
Intended Tax Treatment. The parties intend It is intended that the Merger to be treated Mergers, taken together, shall qualify as a reorganization under “reorganization” within the meaning of Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and that the rules Acquisition Agreement and regulations thereunder, and intend for this Agreement to shall together constitute and be adopted as a “plan of reorganization” within the meaning of the CodeTreasury Regulations §§ 1.368-2(g) and 1.368-3(a).
Appears in 1 contract
Intended Tax Treatment. The parties intend the Merger to be treated as a reorganization under Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”), 1986 and the rules and regulations thereunder, thereunder (the "Code") and intend for this Agreement to constitute a “"plan of reorganization” " within the meaning of the Code.
Appears in 1 contract
Intended Tax Treatment. The parties intend the Merger to be treated as a reorganization under Section 368(a) of the Internal Revenue Code of 1986, as amended 1986 (the “Code”), and the rules and regulations thereunder, and intend for this Agreement to constitute a “plan of reorganization” within the meaning of the Code.
Appears in 1 contract
Samples: Agreement and Plan of Merger (Central Pacific Financial Corp)
