Intended Tax Treatment. For U.S. federal, and applicable state and local income tax purposes each of the contributions of Rollover Shares hereunder, taken collectively, shall be treated as an integrated transaction qualifying under Section 351(a) of the Internal Revenue Code of 1986, as amended.
Appears in 6 contracts
Samples: Joinder Agreement (NGM Biopharmaceuticals Inc), Rollover Agreement (NGM Biopharmaceuticals Inc), Joinder Agreement (Column Group L P)
Intended Tax Treatment. For U.S. federal, and applicable state and local income tax purposes each of the contributions of Rollover Shares hereunderContributions and the Cash Contributions, taken collectively, together with the contributions and exchanges pursuant to Section 2.1 of the Incentive Rollover Agreements, shall be treated as an integrated transaction qualifying under Section 351(a) of the Internal Revenue Code of 1986, as amended.
Appears in 3 contracts
Samples: Contribution and Subscription Agreement (General Atlantic, L.P.), Contribution and Subscription Agreement (Brasil De Sa Cavalcante Oto), Contribution and Subscription Agreement (De Sa Cavalcante Neto Ari)
