ABI GROUP AND ALTRIA TAX OBLIGATIONS. 3.1 ABI and each ABI Affiliate will comply with all reporting and record-keeping requirements applicable to the Reorganization or the Recapitalization that are prescribed by the Code, the Treasury Regulations, or by forms, instructions, or other publications of the IRS. Neither ABI nor any ABI Affiliate will take any position on any Federal, state or local income or franchise Tax Return, or take any other Federal, state or local income or franchise Tax reporting position that is inconsistent with the treatment of the Reorganization or Recapitalization as tax-free reorganizations within the meaning of Section 368 of the Code.
Appears in 5 contracts
Samples: Tax Matters Agreement, Tax Matters Agreement (Altria Group, Inc.), Tax Matters Agreement (Anheuser-Busch InBev S.A.)
ABI GROUP AND ALTRIA TAX OBLIGATIONS. 3.1 ABI and each ABI Affiliate will comply with all reporting and record-keeping requirements applicable to the Reorganization or the Recapitalization that are prescribed by the Code, the Treasury Regulations, or by forms, instructions, or other publications of the IRS. Neither ABI nor any ABI Affiliate will take any position on any Federal, state or local income or franchise Tax Return, or take any other Federal, state or local income or franchise Tax reporting position that is inconsistent with the treatment of the Reorganization or Recapitalization as tax-tax- free reorganizations within the meaning of Section 368 of the Code.
Appears in 1 contract
Samples: Tax Matters Agreement
