Tax Opinions. (i) The acquisition by the Acquiring Fund of substantially all of the assets of the Target Fund, as provided for in the Agreement, in exchange for Acquiring Fund shares and the assumption by the Acquiring Fund of all of the liabilities of the Target Fund, followed by the distribution by the Target Fund to its shareholders of the Acquiring Fund shares in complete liquidation of the Target Fund, will qualify as a reorganization within the meaning of Section 368(a)(1) of the Code, and the Target Fund and the Acquiring Fund each will be a "party to the reorganization" within the meaning of Section 368(b) of the Code.
Appears in 21 contracts
Samples: Agreement and Plan of Reorganization (Aim Sector Funds (Invesco Sector Funds)), Agreement and Plan of Reorganization (Aim Counselor Series Trust (Invesco Counselor Series Trust)), Agreement and Plan of Reorganization (Aim Investment Securities Funds (Invesco Investment Securities Funds))
Tax Opinions. (i) The acquisition by the Acquiring Fund of substantially all of the assets of the Target Fund, as provided for in the Agreement, in exchange for Acquiring Fund shares and the assumption by the Acquiring Fund of all of the liabilities of the Target Fund, followed by the distribution by the Target Fund to its shareholders of the Acquiring Fund shares in complete liquidation of the Target Fund, will qualify as a reorganization within the meaning of Section 368(a)(1) of the Code, and the Target Fund and the Acquiring Fund each will be a "“party to the reorganization" ” within the meaning of Section 368(b) of the Code.
Appears in 4 contracts
Samples: Agreement and Plan of Reorganization (Aim Investment Securities Funds (Invesco Investment Securities Funds)), Agreement and Plan of Reorganization (Aim Counselor Series Trust (Invesco Counselor Series Trust)), Agreement and Plan of Reorganization (Aim Tax Exempt Funds (Invesco Tax-Exempt Funds))
Tax Opinions. (i) The acquisition by the Acquiring Fund of substantially all of the assets of the Target Fund, as provided for in the Agreement, in exchange for Acquiring Fund shares and the assumption by the Acquiring Fund of all of the liabilities of the Target Fund, followed by the distribution by the Target Fund to its shareholders of the Acquiring Fund shares in complete liquidation of the Target Fund, will qualify as a reorganization within the meaning of Section 368(a)(1368 (a)(1) of the Code, and the Target Fund and the Acquiring Fund each will be a "party to the reorganization" within the meaning of Section 368(b) of the Code.
Appears in 1 contract
Tax Opinions. (i) The acquisition by the Acquiring Fund of substantially all of the assets of the Target Fund, as provided for in the Agreement, in exchange for Acquiring Fund shares and the assumption by the Acquiring Fund of all of the liabilities of the Target Fund, followed by the distribution by the Target Fund to its shareholders of the Acquiring Fund shares in complete liquidation of the Target Fund, will qualify as a reorganization within the meaning of Section 368(a)(1368(a)(1)(F) of the Code, and the Target Fund and the Acquiring Fund each will be a "party to the reorganization" within the meaning of Section 368(b) of the Code.
Appears in 1 contract
Samples: Agreement and Plan (Aim Equity Funds (Invesco Equity Funds))
