Qualification as Reorganization. For U.S. federal income tax purposes, (1) the CoffeeCo Contribution, the Distribution and the Debt Exchange are intended to qualify as a reorganization under Sections 368(a), 355 and 361 of the Code and (2) it is the expectation of the parties hereto that the Merger is a reorganization within the meaning of Section 368(a) of the Code that is taxable to U.S. stockholders under Section 367 of the Code.
Appears in 3 contracts
Sources: Master Separation Agreement, Master Separation Agreement (Sara Lee Corp), Master Separation Agreement (D.E Master Blenders 1753 B.V.)