Acquired Subsidiaries. If any Person becomes a Subsidiary of any member of the Splitco Group in any transaction after the Distribution (and such Person was not a member of the Splitco Group or the Distributing Group prior to such transaction) (a “Splitco Acquired Subsidiary”), then any Taxes and Tax Items of such Splitco Acquired Subsidiary for any Tax Year (or portion thereof) ending on or prior to the date of such transaction shall be allocated to Splitco. If any Person becomes a Subsidiary of any member of the Distributing Group in any transaction after the Distribution (and such Person was not a member of the Splitco Group or the Distributing Group prior to such transaction) (a “Distributing Acquired Subsidiary”), then any Taxes and Tax Items of such Distributing Acquired Subsidiary for any Tax Year (or portion thereof) ending on or prior to the date of such transaction shall be allocated to Distributing.
Appears in 8 contracts
Samples: Tax Sharing Agreement, Tax Sharing Agreement, Tax Sharing Agreement (Gci Liberty, Inc.)
Acquired Subsidiaries. If any Person becomes a Subsidiary of any member of the Splitco Group in any transaction after the Distribution (and such Person was not a member of the Splitco Group or the Distributing Group prior to such transaction) (a “Splitco Acquired Subsidiary”), then any Taxes and Tax Items of such Splitco Acquired Subsidiary for any Tax Year Period (or portion thereof) ending on or prior to the date of such transaction shall be allocated to Splitco. If any Person becomes a Subsidiary of any member of the Distributing Group in any transaction after the Distribution (and such Person was not a member of the Splitco Group or the Distributing Group prior to such transaction) (a “Distributing Acquired Subsidiary”), then any Taxes and Tax Items of such Distributing Acquired Subsidiary for any Tax Year Period (or portion thereof) ending on or prior to the date of such transaction shall be allocated to Distributing.
Appears in 5 contracts
Samples: Tax Sharing Agreement (Sirius Xm Holdings Inc.), Tax Sharing Agreement (Liberty Media Corp), Tax Sharing Agreement (Atlanta Braves Holdings, Inc.)
Acquired Subsidiaries. If any Person becomes a Subsidiary of any member of the Splitco Spinco Group in any transaction after the Distribution (and such Person was not a member of the Splitco Spinco Group or the Distributing Group prior to such transaction) (a “Splitco Spinco Acquired Subsidiary”), then any Taxes and Tax Items of such Splitco Spinco Acquired Subsidiary for any Tax Year (or portion thereof) ending on or prior to the date of such transaction shall be allocated to SplitcoSpinco. If any Person becomes a Subsidiary of any member of the Distributing Group in any transaction after the Distribution (and such Person was not a member of the Splitco Spinco Group or the Distributing Group prior to such transaction) (a “Distributing Acquired Subsidiary”), then any Taxes and Tax Items of such Distributing Acquired Subsidiary for any Tax Year (or portion thereof) ending on or prior to the date of such transaction shall be allocated to Distributing.
Appears in 3 contracts
Samples: Tax Sharing Agreement, Tax Sharing Agreement (Starz), Tax Sharing Agreement (Liberty Spinco, Inc.)
Acquired Subsidiaries. If any Person becomes a Subsidiary of any member of the Splitco Controlled Group in any transaction after the Distribution (and such Person was not a member of the Splitco Controlled Group or the Distributing Group prior to such transaction) (a “Splitco "Controlled Acquired Subsidiary”"), then any Taxes and Tax Items of such Splitco Controlled Acquired Subsidiary for any Tax Year (or portion thereof) ending on or prior to the date of such transaction shall be allocated to SplitcoControlled. If any Person becomes a Subsidiary of any member of the Distributing Group in any transaction after the Distribution (and such Person was not a member of the Splitco Controlled Group or the Distributing Group prior to such transaction) (a “"Distributing Acquired Subsidiary”"), then any Taxes and Tax Items of such Distributing Acquired Subsidiary for any Tax Year (or portion thereof) ending on or prior to the date of such transaction shall be allocated to Distributing.
Appears in 3 contracts
Samples: Tax Sharing Agreement (Liberty Splitco, Inc.), Tax Sharing Agreement (Liberty Splitco, Inc.), Tax Sharing Agreement (Liberty Splitco, Inc.)
Acquired Subsidiaries. If any Person becomes a Subsidiary of any member of the Splitco Controlled Group in any transaction after the Distribution (and such Person was not a member of the Splitco Controlled Group or the Distributing Group prior to such transaction) (a “Splitco Controlled Acquired Subsidiary”), then any Taxes and Tax Items of such Splitco Controlled Acquired Subsidiary for any Tax Year (or portion thereof) ending on or prior to the date of such transaction shall be allocated to SplitcoControlled. If any Person becomes a Subsidiary of any member of the Distributing Group in any transaction after the Distribution (and such Person was not a member of the Splitco Controlled Group or the Distributing Group prior to such transaction) (a “Distributing Acquired Subsidiary”), then any Taxes and Tax Items of such Distributing Acquired Subsidiary for any Tax Year (or portion thereof) ending on or prior to the date of such transaction shall be allocated to Distributing.
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