Common use of Allocation in Straddle Periods Clause in Contracts

Allocation in Straddle Periods. For purposes of Section 2.1 and Section 2.2, Tax Items arising during any Tax Year that begins on or before and ends after the Spin-off Date shall be treated as arising during the Pre-Distribution Tax Period or the Post-Distribution Tax Period based on an interim closing of the books as of and including the day of the Spin-off Date. Notwithstanding the foregoing, Tax Items attributable to any such Tax Year that are calculated on an annualized basis (including depreciation, amortization and depletion deductions) shall be apportioned between the Pre-Distribution Tax Period and the Post-Distribution Tax Period on a daily pro rata basis.

Allocation in Straddle Periods. For purposes of Section 2.1 2.1(b) and Section 2.22.2(b), Tax Items Benefits arising during any Tax Year that begins on or before and ends after the Spin-off Date shall be treated as arising during the Pre-Distribution Tax Spin Period or the Post-Distribution Tax Spin Period based on an interim closing of the books as of and including the day of the Spin-off Date. Notwithstanding the foregoing, Tax Items attributable to any such Tax Year that are calculated on an annualized basis (including depreciation, amortization and depletion deductions) shall be apportioned between the Pre-Distribution Tax Spin Period and the Post-Distribution Tax Spin Period on a daily pro rata basis.

Allocation in Straddle Periods. For purposes of Section 2.1 ‎Section 2.1(b) and Section 2.2‎Section 2.2(b), Tax Items Benefits arising during any Tax Year that begins on or before and ends after the Spin-off Date shall be treated as arising during the Pre-Distribution Tax Spin Period or the Post-Distribution Tax Spin Period based on an interim closing of the books as of and including the day of the Spin-off Date. Notwithstanding the foregoing, Tax Items attributable to any such Tax Year that are calculated on an annualized basis (including depreciation, amortization and depletion deductions) shall be apportioned between the Pre-Distribution Tax Spin Period and the Post-Distribution Tax Spin Period on a daily pro rata basis.