Distribution Taxes

Distribution Taxes. Means any and all Taxes incurred as a result of (a) the failure of the Distribution to qualify as a tax-free distribution to Delta's stockholders under Section 355(a) of the Code, (b) the failure of the Separation or any Internal Distribution to qualify as a tax-free transaction under Section 368(a)(1)(D) and/or Section 355 of the Code or (c) the failure of the stock of Ultra distributed in the Distribution (or the stock of any Ultra Subsidiary or Delta Subsidiary distributed in any Internal... Distribution) be treated as qualified property pursuant to Section 355(e) of the Code. View More