definiens: within the meaning of Treasury Regulations Section1.368 - 1(d)(4)(ii ) ( the ), will continue at least one signiﬁcant historic business line of Company, or use at least asigniﬁcant portion of the historic business assets of Company in a business, in each case within the meaning of Treasury RegulationsSection 1.368 - 1(d ), except that the historic business assets of Company may be transferred ( i ) to a corporation that is another memberof Parent ’s Qualiﬁed Group, or ( ii ) to an entity subject to federal income Tax as a partnership if ( A ) one or more members of Parent’sQualiﬁed Group have active and substantial management functions as a partner with respect to such historic business or historicbusiness assets of Company, or ( B ) members of Parent ’s Qualiﬁed Group in the aggregate own an interest in the partnershiprepresenting a signiﬁcant interest in the historic business or historic business assets of Company, in each case within the meaning ofTreasury Regulations Section 1.368 - 1(d)(4)(iii )