Qualification as Reorganization. The parties hereto hereby agree that this transaction is intended to qualify as a reorganization within the meaning of Section 368(a)(1)(C) of the Internal Revenue Code of 1986, as amended ("C Reorganization"). Each of the parties agrees that it shall report the transaction as a C Reorganization on its respective federal income tax return, and shall cooperate to the extent reasonably necessary to complete all information reporting necessary in connection therewith.
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Qualification as Reorganization. The parties hereto hereby agree that this transaction is intended to qualify as a reorganization within the meaning of Section 368(a)(1)(C368(a)(1)(A) of the Internal Revenue Code of 1986, as amended ("C A Reorganization"). Each of the parties agrees that it shall report the transaction as a C an A Reorganization on its respective federal income tax return, and shall cooperate to the extent reasonably necessary to complete all information reporting necessary in connection therewith.
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Qualification as Reorganization. The parties hereto hereby agree that this transaction is intended to qualify as a reorganization within the meaning of Section 368(a)(1)(C368(a)(1) of the Internal Revenue Code of 1986, as amended ("C Reorganization"). Each of the parties agrees that it shall report the transaction as a C Reorganization on its respective federal income tax return, and shall cooperate to the extent reasonably necessary to complete all information reporting necessary in connection therewith.
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Sources: Reorganization Agreement (United Information Systems Inc)