definiens: or a ( within the meaning of Section 355(a)(1)(A ) of the Code ) in adistribution of stock intended to qualify for tax - free treatment under Section 355 of the Code(or any similar provision of state, local, or non - U.S. law ) in the two years prior to the date ofthis Agreement ; ( H)none of Warner Chilcott or any of its Subsidiaries has any liability for Taxes of any Person(other than Warner Chilcott or any of its Subsidiaries ) under U.S. Treasury Regulation § 1.1502 - 6 ( or any similar provision of state, local, or non - U.S. law ), as transferee orsuccessor, by contract or otherwise ; ( I)there are no liens for Taxes upon any property or assets of Warner Chilcott or any of itsSubsidiaries, except for Warner Chilcott Permitted Liens ; ( J)no private letter rulings, technical advice memoranda, or similar agreements or rulings havebeen entered into or issued by any Tax Authority with respect to Warner Chilcott or any of itsSubsidiaries for any taxable year for which the statute of limitations has not yet expired ; ( K)neither Warner Chilcott nor any of its Subsidiaries has knowledge of any fact, or has taken oragreed to take any action that would reasonably be expected to prevent or impede the receiptof the Scheme Consideration in exchange for the Warner Chilcott Shares pursuant to theScheme from qualifying as a within the meaning of Section 368(a ) of theCode ; and ( L)Warner Chilcott is in compliance with the 2006 and 2009 Tax Grants, as amended, issuedfrom the Commonwealth of Puerto Rico Department of State Office of Industrial TaxExemption