M&A
confidence high
sentiment positive
materiality 0.75
Glatfelter and Berry waive IRS ruling & tax opinion conditions to close HHNF merger
Magnera Corp
- Waived condition for IRS private letter ruling on tax treatment of the spin-off and merger.
- Berry believes any taxable gain from spin-off would be immaterial based on adjusted tax basis.
- Parties amended Tax Matters Agreement to reflect waivers and clarify liability for transaction taxes.
- Bryan Cave Leighton Paisner LLP tax opinion filed as Exhibit 8.1 supersedes prior opinion.
- Transaction to combine Berry's nonwovens with Glatfelter and rename to Magnera remains subject to other closing conditions.