Allocation Between Taxable Periods. If applicable law requires the Taxable Period of any FTD Group Member that was a member of the UOL Tax Group prior to the Distribution Date to end as of the close of the Distribution Date, then Tax Items shall be included in each Taxable Period in accordance with Treasury Regulation § 1.1502-76(b)(2)(i) with no election under Treasury Regulation § 1.1502-76(b)(2)(ii).
Appears in 4 contracts
Samples: Tax Sharing Agreement (FTD Companies, Inc.), Tax Sharing Agreement (United Online Inc), Sharing Agreement (FTD Companies, Inc.)
