Certain Post-Distribution Transactions. (a) (i) -------------------------------------- Florida Progress shall comply, and shall cause each member of the Florida Progress Group to comply, with and otherwise not take action inconsistent with each representation and statement made with respect to Florida Progress or any other member of the Florida Progress Group to the Internal Revenue Service in connection with the request by Florida Progress for a ruling letter in respect of the Distribution as to certain tax aspects of the Distribution and (ii) until two years after the Distribution Date, Florida Progress will maintain its status as a company engaged in the active conduct of a trade or business, as defined in Section 355(b) of the Code. (i) Echelon shall comply with and otherwise not take action inconsistent with each representation and statement made with respect to Echelon to the Internal Revenue Service in connection with the request by Florida Progress for a ruling letter in respect of the Distribution as to certain tax aspects of the Distribution and (ii) until two years after the Distribution Date, Echelon will maintain its status as a company engaged in the active conduct of a trade or business, as defined in Section 355(b) of the Code.
Appears in 2 contracts
Sources: Distribution Agreement (Florida Power Corp /), Distribution Agreement (Echelon International Corp)