Treatment of Transactions. The parties shall report the Transactions for all Tax purposes in a manner consistent with the Tax Opinion, unless, and then only to the extent, an alternative position is required pursuant to a Final Determination. Except in the case of a WRECO Separate Return, a Transfer Tax Return and a Tax Return of the RMT Group, Weyerhaeuser shall determine the Tax reporting of any issue relating to the Transactions that is not covered by the Tax Opinion.
Treatment of Transactions. Each of the undersigned elects that the consummation of the transactions contemplated by the Merger and Contribution Agreement and the other agreements contemplated by the Merger and Contribution Agreement, including but not limited to the Liquidation Agreement, will not be deemed a liquidation for purposes of Sections 3.1 and 3.2 of the Statement with Respect to Shares filed by Zynaxis in the Department of State of the Commonwealth of Pennsylvania on April 6, 1995.
Treatment of Transactions. 16 4. Preparation and Delivery of Disclosure Schedule.........................................................16
Treatment of Transactions. The transactions contemplated by this Agreement shall be treated for Tax purposes as an acquisition by Team of stock, and shall not be treated for Tax purposes as an asset acquisition. Team shall take no position or action other than in accordance with such treatment.
Treatment of Transactions. The parties shall report the Transactions for all Tax purposes in a manner consistent with the Tax Opinion, unless, and then only to the extent, an alternative position is required pursuant to a Final Determination. Subject to Section 3.01(b), and except in the case of a Folgers Separate Return for a Straddle Period, P&G shall determine the Tax reporting of any issue relating to the Transactions that is not covered by the Tax Opinion.
Treatment of Transactions. The Transferor will maintain its records and books of account in a manner that clearly reflects the true contribution of all Transferred Receivables conveyed to Transferee hereunder. So long as any Transferred Receivable remains outstanding, all of the published financial statements of Transferor will contain a footnote (i) disclosing the transactions contemplated hereunder which unambiguously describes the contribution of Transferred Receivables to the capital of the Borrower as an absolute transfer and the interest of Transferee and the Agent in the Transferred Receivables, and (ii) expressly stating that the Transferred Receivables are unavailable for creditors of the Transferor.
Treatment of Transactions. 12 SECTION 2.07.
Treatment of Transactions. For all purposes under the Code and the Regulations, for purposes of maintaining the capital accounts under Article 4 of the LLC Agreement and for purposes of calculating financial results of the Company and its Subsidiaries, the Separately Held Assets, the Shell Plantation Interest, the Texaco Colonial Interest and all other assets with respect to which Economic Benefits and Detriments were transferred in accordance with this Agreement shall be deemed to be contributed to the Company as of the Effective Time. After the Effective Time, all items of income, gain, loss or deduction relating to such assets shall be deemed to be items derived or incurred by the Company. No adjustments to capital accounts shall be made with respect to any payments made pursuant to Section 4.01(c) or 4.01(d), as the case may be.
Treatment of Transactions. The parties acknowledge and agree (i) to treat the transactions contemplated by this Agreement for federal income tax purposes as a contribution to capital, in accordance with its form, and (ii) that none of Partner Corp., General Partner, and Management LLC is selling any portion of its partnership interest in the Partnership to Strategic, and, accordingly, the parties shall not treat the transactions contemplated by this Agreement as a sale of interest for any purpose.
Treatment of Transactions. Each of Medco and PAID shall xxxx its books and records to reflect the transaction effected pursuant hereto as, including for accounting purposes, a sale, transfer, conveyance, grant and assignment by PAID to Medco of PAID's right, title and interest in any and all Client Receivables (including all proceeds thereof and the right to receive all payments made or to be made in respect thereof) that may from time to time be held by, or owing or payable to, PAID in exchange for Medco's assumption and agreement to pay, perform, and discharge in full in accordance with their terms, all Pharmacy Payables that may from time to time be owing or payable (other than Pharmacy Payables outstanding as of the date hereof with a balance equal to the Contribution Amount).
