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Plz help me answer the questions in green 1. 2. RFH Contribution to EED Result Exelon Corporation Exelon Corporation Subsequent to the Initial Merger, Distribution,
Plz help me answer the questions in green
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RFH Contribution to EED Result Exelon Corporation Exelon Corporation Subsequent to the Initial Merger, Distribution, and Upstream Merger, Exelon contributed its equity interests in RF Holdco to EED in the "RFH Contribution" EED RF Holdco EED RF Holdco BG&E BG&E ComEd PECO Are there any federal income tax consequences of the RFH Contribution? Contribution of CEG SUBS** to EVC & ExGen Result Exelon Corporation Exelon Corporation EVC Following the consummation of the Initial Merger, Distribution, Upstream Merger, and RFH Contribution, Exelon concurrently contributed all its equity interests in the CEG SUBS to EVC and then EVC contributed such interests to ExGen in the "Contribution" CEG SUBS** EVC ExGen ExGen Are there any federal income tax consequences of the Contribution? CEG SUBS** ** CEG SUBS: (1) Constellation Energy Resources, LLC (disregarded for federal and state income tax purposes); (ii) Constellation Nuclear, LLC (classified as a C corporation for federal and state income tax purposes); and (iii) Constellation Holdings, Inc. RFH Contribution to EED Result Exelon Corporation Exelon Corporation Subsequent to the Initial Merger, Distribution, and Upstream Merger, Exelon contributed its equity interests in RF Holdco to EED in the "RFH Contribution" EED RF Holdco EED RF Holdco BG&E BG&E ComEd PECO Are there any federal income tax consequences of the RFH Contribution? Contribution of CEG SUBS** to EVC & ExGen Result Exelon Corporation Exelon Corporation EVC Following the consummation of the Initial Merger, Distribution, Upstream Merger, and RFH Contribution, Exelon concurrently contributed all its equity interests in the CEG SUBS to EVC and then EVC contributed such interests to ExGen in the "Contribution" CEG SUBS** EVC ExGen ExGen Are there any federal income tax consequences of the Contribution? CEG SUBS** ** CEG SUBS: (1) Constellation Energy Resources, LLC (disregarded for federal and state income tax purposes); (ii) Constellation Nuclear, LLC (classified as a C corporation for federal and state income tax purposes); and (iii) Constellation Holdings, IncStep by Step Solution
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