definiens: of a transaction means the purported or claimed federal income tax treatment o f the transaction, and ( ii ) the of a transaction means any fact that may be relevant to understandin g the purported or claimed federal income tax treat ment of the transaction . Thus, for the avoidance of doubt, the Parties acknowledge and agree that the tax trea tment and tax structure of any transaction does not include t he name of any Party to a transaction or any sensit i ve business information ( including, without limitation, the nam e and other specific information about any Party ’s intellectual property or other proprietary assets ) unless such i nformation may be related or relevant to the purpor ted or claimed federal income tax treatment of the transac tion . The Party required to disclose Confidential I nformation under this Section 8.5 will first give prompt notic e to the other Party hereto to enable it to seek an y available exemptions from or limitations on such disclosure r equirement and will reasonably cooperate in such ef forts by the Party