Allocation of Consolidated Federal Income Tax Liability Sample Clauses

Allocation of Consolidated Federal Income Tax Liability. The Genworth Companies shall allocate the federal income tax liability of the Consolidated Group to each Member by multiplying the Consolidated Federal Income Tax Liability times a fraction, the numerator of which is the Member’s Separate Federal Income Tax Liability and the denominator of which is the sum of the Separate Federal Income Tax Liabilities of the Genworth Companies. The amount of the Consolidated Federal Income Tax Liability allocated to each Member shall not exceed the Separate Federal Income Tax Liability of such Member; provided, however, that for purposes of computing the Separate Federal Income Tax Liability of a Member, any income, deduction, or loss recognized by such Member in an intercompany transaction with another Member shall be taken into account as provided in Treasury Regulation § 1.1502-13.
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Allocation of Consolidated Federal Income Tax Liability. In lieu of making tax payments, the Members shall make payments to and receive payments from Newco as follows:
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Allocation of Consolidated Federal Income Tax Liability. (a) The tax liability of the Affiliated Group will be first allocated to the members in accordance with section 1.1552-1(a)(2) of the Federal income tax regulations and then the Affiliated Group will elect I00 percent as a fixed percentage to be used to allocate additional amounts to the members in accordance with Treasury Regulations Section 1.1502-33(d)(3)(i). Each Subsidiary will pay to the Parent the amount of tax liability allocated to it in this paragraph (after the adjustments provided for in subparagraph (e)) and Parent will pay to each Subsidiary or former Subsidiary all amounts allocable under section 1.1502-33(d)(3)(ii).
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Allocation of Consolidated Federal Income Tax Liability. (a) If a consolidated federal income tax return is filed by Parent on behalf of the Company Group for any taxable year, Subsidiary shall pay to Parent an amount equal to its Hypothetical Tax Liability for such taxable year. Parent shall provide to Subsidiary a schedule that sets forth in reasonable detail the calculation of its Hypothetical Tax Liability for such taxable year.
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Allocation of Consolidated Federal Income Tax Liability. For each Taxable Year subject to this Agreement, the consolidated Federal income tax liability of the Group shall be allocated among the members as follows:
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Allocation of Consolidated Federal Income Tax Liability. For so long as Vysis shall continue to be an Amoco Member, every Vysis Member that is an Amoco Member shall remain subject to the Amoco Allocation Methodology. Consistently with that methodology, it is understood and agreed that Amoco shall not be required to credit or reimburse any Vysis Member for any tax benefit Amoco has received or may receive as a result of deductions or losses attributable to any Vysis Member for any year prior to 1996. However, for any taxable year, including a partial year, beginning in 1996 and ending on the Federal Deconsolidation Date, in which the Vysis Group in the aggregate has deductions or losses which provide a tax benefit to Amoco, computed in a manner consistent with the Amoco Allocation Methodology, Amoco shall reimburse Vysis for such tax benefit by reducing, by the amount of the benefit, the Vysis equity or debt to which Amoco would otherwise have been or will be entitled as a result of its incremental funding of Vysis. Amoco shall not, however, be required to reimburse Vysis for any research credits or any other tax credits which Amoco may claim, whether or not based in whole or in part on activities conducted by Vysis. Vysis Members leaving the Amoco Affiliated Group during a taxable year shall not retain any tax attributes acquired while an Amoco Member except those attributes specifically addressed in section 1.1502-79 of the Regulations.
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Allocation of Consolidated Federal Income Tax Liability. (a) Except as otherwise provided in paragraph 3(c), RHC and RBH agree that RBH shall pay to RHC an amount (not less than zero) equal to the Separate Tax Liability of RBH. The "Separate Tax Liability" of RBH shall be the federal Tax liability of RBH for the taxable period, determined as if RBH were at all times subject to federal income taxation as a separate taxpayer, not included or includable in the RHC Group ( or in any other consolidated group); provided, however that such determination shall be made without regard to any carrybacks or carryforwards of any tax attributes of RBH (including without limitation net operating losses) that would be available to it if it, at all times, had filed a separate federal income tax return, but which in fact are not available under applicable federal income tax law as a result of its inclusion in the RHC Group, provided, further, that: (i) such determination shall be made by giving effect to the modifications listed in Treasury regulation Section 1.1552-1 (a) (2) (ii); (ii) such determination shall be computed using the highest marginal corporate Tax rate in effect for such taxable period; (iii) if, for any taxable period, a Tax would be imposed on RBH pursuant to Section 55 of the Code, the Separate Tax Liability of RBH shall be increased by the amount of Tax that would be imposed on RBH under such Code section, computed using the alternative minimum tax rate set forth in Section 55(b)(1) of the Code and taking into account items specified in Section 55(b) (2) of the Code attributable to RBH; (iv) such determination shall be made using the same elections and methods of accounting as are used in determining the consolidated federal income tax liability of the RHC Group for such taxable period; and (v) notwithstanding any provision herein to the contrary, in no event shall RBH be required to make any payment hereunder to the extent that, prior to giving effect to the Operating Agreement, such payment would cause (or increase ) a violation of any "minimum bankroll requirement," or other applicable gaming obligation, except to the extent such payment constitutes RBH's share of the RHC Group's federal income tax liability based on its contribution to the RHC Group's consolidated taxable income (as such contribution would be determined under Treasury Regulation Section 1.1552-1 ( a)(1 ), regardless of whether such regulation is actually applicable to the RHC Group for any purpose) or is otherwise required of RBH under app...
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Allocation of Consolidated Federal Income Tax Liability. (a) If a consolidated federal income tax return is filed by HCC on behalf of the Company Group for any taxable year, each Subsidiary shall pay to HCC an amount equal to its Hypothetical Tax Liability for such taxable year. HCC shall provide to each Subsidiary a schedule that sets forth in reasonable detail the calculation of its Hypothetical Tax Liability for such taxable year.
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Allocation of Consolidated Federal Income Tax Liability. If a consolidated federal income tax return is filed by Parent on behalf of the IPC Group for any Post-1998 Taxable Year:
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Related to Allocation of Consolidated Federal Income Tax Liability

  • Income Tax Liability Within ten Business Days after the receipt of revenue agent reports or other written proposals, determinations or assessments of the IRS or any other taxing authority which propose, determine or otherwise set forth positive adjustments to the Tax liability of any “affiliated group” (within the meaning of Section 1504(a)(l) of the Code) which equal or exceed $1,000,000 in the aggregate, telephonic or telecopied notice (confirmed in writing within five Business Days) specifying the nature of the items giving rise to such adjustments and the amounts thereof.

  • Federal Income Tax Allocations Net income of the Trust for any month as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) during which the beneficial ownership interests in the Trust are held by more than one Person shall be allocated:

  • Allocation of Tax Liability In the event that any tax is imposed on the Trust, such tax shall be charged against amounts otherwise distributable to the Owners in proportion to their respective Sharing Ratios. The Owner Trustee is hereby authorized to retain from amounts otherwise distributable to the Owners sufficient funds to pay or provide for the payment of, and then to pay, such tax as is legally owed by the Trust (but such authorization shall not prevent the Owner Trustee from contesting any such tax in appropriate proceedings, and withholding payment of such tax, if permitted by law, pending the outcome of such proceedings).

  • Distributions Upon Income Inclusion Under Section 409A of the Code Upon the inclusion of any portion of the benefits payable pursuant to this Agreement into the Executive’s income as a result of the failure of this non-qualified deferred compensation plan to comply with the requirements of Section 409A of the Code, to the extent such tax liability can be covered by the Executive’s vested accrued liability, a distribution shall be made as soon as is administratively practicable following the discovery of the plan failure.

  • Income Tax Allocations (a) Except as provided in this Section 4.3, each item of income, gain, loss and deduction of the Company for federal income tax purposes shall be allocated among the Members in the same manner as such items are allocated for Capital Account purposes under Section 4.1 and Section 4.2.

  • Treatment of Tax Indemnity and Tax Benefit Payments In the absence of any change in Tax treatment under the Code or other applicable Tax Law,

  • Allocation of Tax Liabilities The provisions of this Section 2 are intended to determine each Company's liability for Taxes with respect to Pre-Distribution Periods. Once the liability has been determined under this Section 2, Section 5 determines the time when payment of the liability is to be made, and whether the payment is to be made to the Tax Authority directly or to another Company.

  • Determination of Net Asset Value, Net Income and Distributions Subject to applicable federal law including the 1940 Act and Section 3.6 hereof, the Trustees, in their sole discretion, may prescribe (and delegate to any officer of the Trust or any other Person or Persons the right and obligation to prescribe) such bases and time (including any methodology or plan) for determining the per Share or net asset value of the Shares of the Trust or any Series or Class or net income attributable to the Shares of the Trust or any Series or Class, or the declaration and payment of dividends and distributions on the Shares of the Trust or any Series or Class and the method of determining the Shareholders to whom dividends and distributions are payable, as they may deem necessary or desirable. Without limiting the generality of the foregoing, but subject to applicable federal law including the 1940 Act, any dividend or distribution may be paid in cash and/or securities or other property, and the composition of any such distribution shall be determined by the Trustees (or by any officer of the Trust or any other Person or Persons to whom such authority has been delegated by the Trustees) and may be different among Shareholders including differences among Shareholders of the same Series or Class.

  • Federal Income Tax Matters The Certificateholders acknowledge that it is their intent and that they understand it is the intent of the Depositor and the Servicer that, for purposes of federal income, State and local income and franchise tax and any other income taxes, the Trust will be treated either as a disregarded entity under Treasury Regulation Section 301.7701-3 or as a partnership, and that the Certificateholders will be treated as partners in that partnership. The Certificateholders by acceptance of a Certificate agree to such treatment and agree to take no action inconsistent with such treatment. For each calendar quarter, other than periods in which there is only one Certificateholder:

  • Federal Income Tax Elections The Member shall make all elections for federal income tax purposes.

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