Owned Real Properties. Delta shall convey or otherwise Transfer to Ultra or its designated Subsidiary, or cause its applicable Subsidiary to convey or otherwise Transfer to Ultra or its designated Subsidiary, and Ultra shall accept, or cause its applicable Subsidiary to accept, all of Delta’s or its Subsidiary’s rights, title and interests in and to the Owned Real Properties, subject to the other provisions of this Agreement and (to the extent not inconsistent with the provisions of this Agreement) the terms of the Separation and Distribution Agreement and the other Ancillary Agreements. The Parties shall use commercially reasonable efforts to effect such conveyance or Transfer on or prior to the Distribution Date or as soon as practicable thereafter. The Parties shall reasonably cooperate in structuring the Transfers in the most tax efficient manner.
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Owned Real Properties. Delta Ultra shall convey or otherwise Transfer to Ultra Delta or its designated Subsidiary, or cause its applicable Subsidiary to convey or otherwise Transfer to Ultra Delta or its designated Subsidiary, and Ultra Delta shall accept, or cause its applicable Subsidiary to accept, all of DeltaUltra’s or its Subsidiary’s rights, title and interests in and to the Owned Real Properties, subject to the other provisions of this Agreement and (to the extent not inconsistent with the provisions of this Agreement) the terms of the Separation and Distribution Agreement and the other Ancillary Agreements. The Parties shall use commercially reasonable efforts to effect such conveyance or Transfer on or prior to the Distribution Date or as soon as practicable thereafter. The Parties shall reasonably cooperate in structuring the Transfers in the most tax efficient manner.
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