These observations assume that the separation will be concluded in accordance with the terms of the separation agreement and are based on the facts set out in the separation agreement, the tax agreement, other ancillary agreements, the relocation prospectus and a number of other documents. In addition, these opinions are based on certain representations in the actual and specific agreements of the company and Barnes & Noble Education. It is not possible to rely on opinions if any of the assumptions, assurances or agreements are erroneous, incomplete or inaccurate or are violated in any way in a significant way. The notices are not binding on the Internal Revenue Service (IRS) or the courts, and we cannot guarantee that the IRS or a court will not take a contrary position. If it were established that the separation does not qualify for non-recording of gains and losses, U.S. holders could be taxable. In this case, any U.S. can. .
- Term Loan Agreement No
- Tlicho Land Claims Agreement