Section 332. The conversion of Merger Sub from a corporation to a limited liability company disregarded as separate from Novume will be treated as a liquidation of Merger Sub. At the time Merger Sub converts to a limited liability company, it will be and has always been wholly owned by Novume. Under Code section 332(a), Novume should not recognize gain or loss upon the liquidation. Under Code section 337(a), Merger Sub should not recognize gain or loss upon the liquidation.
Appears in 2 contracts
Sources: Agreement and Plan of Merger (Novume Solutions, Inc.), Agreement and Plan of Merger (Novume Solutions, Inc.)