Qualification as Reorganization. The Merger is intended to qualify as a reorganization under Section 368(a) of the Code. It is the expectation of the parties that the Merger is taxable to U.S. stockholders under Section 367 of the Code.
Appears in 2 contracts
Sources: Merger Agreement (D.E Master Blenders 1753 N.V.), Master Separation Agreement (D.E Master Blenders 1753 B.V.)