Reportable Transactions. Neither the Company nor any of its Subsidiaries has entered into any transaction that constitutes (i) a “reportable transaction” within the meaning of Treasury Regulation § 1.6011-4(b), (ii) a “confidential tax shelter” within the meaning of Treasury Regulation § 301.6111-2(a)(2) or a “potentially abusive tax shelter” within the meaning of Treasury Regulation § 301.6112-1(b).
Appears in 2 contracts
Sources: Merger Agreement (Harber Lacy J), Merger Agreement (Timco Aviation Services Inc)
Reportable Transactions. Neither the Company nor any of its Subsidiaries has entered into any transaction that constitutes (i) a “"reportable transaction” " within the meaning of Treasury Regulation § ss. 1.6011-4(b), (ii) a “"confidential tax shelter” " within the meaning of Treasury Regulation § ss. 301.6111-2(a)(2) or a “"potentially abusive tax shelter” " within the meaning of Treasury Regulation § ss. 301.6112-1(b).
Appears in 1 contract
Sources: Merger Agreement (Owl Creek I Lp)
Reportable Transactions. Neither the Company nor any of its Subsidiaries has entered into any transaction that constitutes (i) a “reportable transaction” within the meaning of Treasury Regulation § 1.6011-4(b), (ii) a “confidential tax shelter” within the meaning of Treasury Regulation § 301.6111-2(a)(2) or (iii) a “potentially abusive tax shelter” within the meaning of Treasury Regulation § 301.6112-1(b).
Appears in 1 contract
Sources: Merger Agreement (Checkers Drive in Restaurants Inc /De)
Reportable Transactions. Neither the Company nor any of its Subsidiaries subsidiaries has entered into any engaged in a reportable transaction that constitutes (i) a “reportable transaction” within the meaning of under Treasury Regulation § Regulations Section 1.6011-4(b), (ii) including a “confidential transaction that is the same as or substantially similar to one of the types of transactions that the IRS has determined to be a tax shelter” within the meaning avoidance transaction and identified by notice, regulation, or other form of published guidance as a listed transaction, as set forth in Treasury Regulation § 301.6111Regulations Section 1.6011-2(a)(2) or a “potentially abusive tax shelter” within the meaning of Treasury Regulation § 301.6112-1(b4(b)(2).
Appears in 1 contract
Sources: Unit Purchase Agreement (Yext, Inc.)
Reportable Transactions. Neither the The Company nor any of its Subsidiaries has not entered into any transaction that constitutes (i) a “reportable transaction” within the meaning of Treasury Regulation § 1.6011-4(b), (ii) a “confidential tax shelter” within the meaning of Treasury Regulation § 301.6111-2(a)(2) or (iii) a “potentially abusive tax shelter” within the meaning of Treasury Regulation § 301.6112-1(b).
Appears in 1 contract
Sources: Merger Agreement (UpSnap, Inc.)