Common use of Intended Tax Treatment Clause in Contracts

Intended Tax Treatment. The Parties acknowledge and agree that, for U.S. federal (and applicable state and local) income Tax purposes, the Merger is intended to qualify as a reorganization within the meaning of Section 368(a) of the Code (the “Intended Tax Treatment”). The Parties adopt this Agreement as a “plan of reorganization” within the meaning of Treasury Regulations Sections 1.368-2(g) and 1.368-3.

Intended Tax Treatment. The Parties acknowledge and agree that, for U.S. federal (and applicable state and local) income Tax purposes, the Merger It is intended to that the Mergers, taken together, shall qualify as a reorganization “reorganization” within the meaning of Section 368(a) of the Code (Code, and that the “Intended Tax Treatment”). The Parties adopt Acquisition Agreement and this Agreement shall together constitute and are adopted as a “plan of reorganization” within the meaning of Treasury Regulations Sections §§ 1.368-2(g) and 1.368-33(a).

Intended Tax Treatment. The Parties acknowledge and agree It is intended that, for U.S. federal (and applicable state and local) income Tax purposes, (a) each of the Merger is intended to Mergers will qualify as a reorganization “reorganization” within the meaning of Section 368(a) of the Code Code, (b) the Mergers together will be treated as an “Intended Tax Treatment”). The Parties adopt exchange” described in Section 351 of the Code, and (c) this Agreement as will constitute a “plan of reorganization” within for purposes of Sections 354 and 361 of the meaning of Treasury Regulations Sections 1.368-2(g) and 1.368-3Code.

Intended Tax Treatment. The Parties acknowledge and agree that, for U.S. federal (and applicable state and local) income Tax purposes, It is intended that the Merger is intended to shall qualify as a reorganization “reorganization” within the meaning of Section 368(a) of the Code, and that this Agreement be, and hereby is, adopted as a “plan of reorganization” for purposes of Sections 354, 361 and 368 of the Code and within the meaning of Treas. Reg. §§ 1.368-2(g) and 1.368-3(a) (the “Intended Tax Treatment”). The Parties adopt this Agreement as a “plan of reorganization” within the meaning of Treasury Regulations Sections 1.368-2(g) and 1.368-3.Article III MERGER CONSIDERATION; CONVERSION OF SECURITIES

Intended Tax Treatment. The Parties acknowledge and agree that, for U.S. For federal (and applicable state and local) income Tax tax purposes, the Merger is intended to qualify parties intend that each of the Mergers will be treated as a reorganization within under the meaning provisions of Section 368(a) of the Internal Revenue Code of 1986, as amended, and the rules and regulations promulgated thereunder (the “Intended Tax TreatmentCode”). The Parties adopt this Agreement as a “plan of reorganization” within the meaning of Treasury Regulations Sections 1.368-2(g) and 1.368-3.

Intended Tax Treatment. The Parties acknowledge and agree that, for U.S. For federal (and applicable state and local) income Tax tax purposes, it is intended that the Merger is intended to qualify will be treated as a reorganization within under the meaning provisions of Section 368(a) of the Internal Revenue Code of 1986, as amended, and the rules and regulations promulgated thereunder (the “Intended Tax Treatment”"Code"). The Parties adopt this Agreement as a “plan of reorganization” within the meaning of Treasury Regulations Sections 1.368-2(g) and 1.368-3.