Extract to table

The Parties intend that the contribution of the Contributed Interests by Contributor to Recipient pursuant to this Agreement shall qualify as a tax-free contribution of property to a partnership in exchange for a partnership interest under Section 721 of the Internal Revenue Code of 1986, as amended (the "Code"), and that no gain or loss shall be recognized by either Party as a result of such contribution; I

As used in this Agreement, the following terms shall have the meanings set forth below

Capitalized terms used but not defined in this Article I shall have the meanings ascribed to them elsewhere in this Agreement or, to the extent not defined herein, in the LLCA

shall be deemed an Affiliate of Contributor solely by reason of its membership interest in or contractual relationship with Solstice Holdings, LLC

Any reference to a specific provision of the Code shall include any successor provision thereto and any Treasury Regulation promulgated under such provision

Unless the context of this Agreement otherwise requires: (a) words of any gender include each other gender; (b) words using the singular or plural number also include the plural or singular number, respectively; (c) the terms "hereof," "herein," "hereby," "hereto," and derivative or similar words refer to this entire Agreement; (d) the terms "Article," "Section," "Schedule," and "Exhibit" refer to the specified Article, Section, Schedule, or Exhibit of or to this Agreement, unless otherwise specified; (e) the word "including" shall mean "including, without limitation"; (f) references to any Person include such Person's successors and permitted assigns; (g) references to any law, statute, rule, or regulation include any amendment, modification, or replacement thereof and any rules, regulations, and interpretive guidance issued thereunder, in each case as in effect from time to time; (h) references to any Section of the Code shall include any successor provision thereto and any Treasury Regulation promulgated under such Section; (i) the word "or" is not exclusive; (j) the word "extent" in the phrase "to the extent" means the degree to which a subject or other thing extends, and such phrase does not mean simply "if"; (k) all dollar amounts are expressed in United States Dollars; and (l) the headings and table of contents contained in this Agreement are for reference purposes only and shall not affect in any way the meaning or interpretation of this Agreement