Allocation of Consolidated Tax Liability Sample Clauses

Allocation of Consolidated Tax Liability. Each of the Parent Group and the Chewy Group shall be allocated a portion of the consolidated U.S. federal income tax liability (if any) of the Parent Consolidated Group by applying the provisions of Section 1552(a)(1) of the Code, determined utilizing the hypothetical taxable income of the Parent Group and the Chewy Group calculated in accordance with the provisions of Treasury Regulations §§ 1.1502-12 and 1.1552-1(a)(1)(ii). The amount calculated under this Section 2.02(b) is the amount that the Parent Group and the Chewy Group, as the case may be, must contribute to the payment of the Parent Consolidated Group’s consolidated U.S. federal income tax liability, with such payment being made in a manner that is consistent with Section 2.06.
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Allocation of Consolidated Tax Liability. The Participating Companies shall allocate the consolidated federal income tax liability of the Affiliated Group (the “Consolidated Tax Liability”) to each Participating Company by multiplying the Consolidated Tax Liability times a fraction, the numerator of which is the federal income tax liability of the Participating Company computed as if the Participating Company filed separate federal income tax returns (“Separate Tax Liability”) and the denominator of which is the sum of the Separate Tax Liabilities of the Participating Companies. The amount of the Consolidated Tax Liability allocated to each Participating Company shall not exceed the Separate Tax Liability of such Participating Company; provided, however, that for purposes of computing the Separate Tax Liability of a Participating Company, any income, deduction, or loss recognized by such Participating Company in an intercompany transaction with another Participating Company shall be taken into account as provided in Treasury Regulation §§ 1.1502-13 and 1.1502-13T.
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Allocation of Consolidated Tax Liability. (a) The Parties shall allocate the Consolidated Tax Liability for each taxable period among the Members and compensate a Member for the use of its net operating losses and/or tax credits in arriving at the Consolidated Tax Liability pursuant to the following steps:
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Allocation of Consolidated Tax Liability. (a) Parent and Subsidiaries agree that the consolidated tax liability for each year, determined in accordance with Income Tax Regulation ("Regulation") 1.1502-2, shall be apportioned among them in accordance with the provisions of Regulation 1.1502-33(d)(3) in conjunction with the method described in Regulation 1.1552-1(a)(2) and allocated pursuant to the following:
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Allocation of Consolidated Tax Liability. With respect to the determination of earnings and profits for federal income tax purposes, the Consolidated Tax Liability for each taxable year shall be allocated among the Members in accordance with the methods prescribed in Treas. Reg. (section)1.1552-1(a)(2) and Treas. Reg. (section)1.1502-33(d)(2)(ii) commencing with the tax year ending February 3, 1996. The fixed percentage to be used for purposes of Treas. Reg. (section)1.1502-33(d)(2)(ii)(b) is 100 percent.
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Allocation of Consolidated Tax Liability. The amount referred to in this paragraph (i) shall be an amount equal to the product of (A) the Consolidated Tax Liability (as defined in subsection (c) below) for such taxable year and (B) a fraction, the numerator of which is the Bank’s Taxable Income (as defined in subsection (c) below) for such taxable year and the denominator of which is the sum of the Taxable Incomes of all Members for such taxable year. This method of allocating Consolidated Tax Liability is intended to conform to the method provided for in Code Section 1552(a)(1) and Regulations Section 1.1552-1(a)(1).
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Allocation of Consolidated Tax Liability. With respect to the determination of earnings and profits for federal income tax purposes, the Consolidated Tax Liability for each taxable year shall be allocated among the Members in accordance with the methods prescribed in Treas. Reg. Section 1.1552-1(a)(2) and Treas. Reg. Section 1.1502-33(d)(2)(ii) commencing with the tax year ending December 31, 1999. The fixed percentage to be used for purposes of Treas. Reg. Section 1.1502-33(d)(2)(ii)(b) is 100 percent.
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Related to Allocation of Consolidated Tax Liability

  • Allocation of Straddle Period Taxes In the case of any Straddle Period:

  • 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).

  • Apportionment of Earnings and Profits and Tax Attributes (a) Tax Attributes arising in a Pre-Distribution Period will be allocated to (and the benefits and burdens of such Tax Attributes will inure to) the members of the Parent Group and the members of the SpinCo Group in accordance with the Code, Treasury regulations and any other Applicable Tax Law, and, in the absence of controlling legal authority or unless otherwise provided under this Agreement, Tax Attributes shall be allocated to the legal entity that created such Tax Attributes.

  • Straddle Period Tax Allocation The Company will, unless prohibited by applicable law, close the taxable period of the Company as of the close of business on the Closing Date. If applicable law does not permit the Company to close its taxable year on the Closing Date or in any case in which a Tax is assessed with respect to a taxable period which includes the Closing Date (but does not begin or end on that day) (a “Straddle Period”), the Taxes, if any, attributable to a Straddle Period shall be allocated (i) to the Selling Members for the period up to and including the close of business on the Closing Date (except that the Members shall not be responsible for Taxes to the extent of any reserve or accrual for Taxes on the Closing Balance Sheet that are included in the Closing Working Capital described in Section 2.4(b)(i)), and (ii) to Purchaser for the period subsequent to the Closing Date. Any allocation of income or deductions required to determine any Taxes attributable to a Straddle Period shall be made by means of a closing of the books and records of the Company as of the close of the Closing Date, provided that exemptions, allowances or deductions that are calculated on an annual basis (including, but not limited to, depreciation and amortization deductions) shall be allocated between the period ending on the Closing Date and the period after the Closing Date in proportion to the number of days in each such period. Property or ad valorem Taxes however shall be apportioned by assuming that an equal portion of such Tax for the entire Straddle Period is allocable to each day in such Straddle Period.

  • Tax Liability The Authorized Participant shall be responsible for the payment of any transfer tax, sales or use tax, stamp tax, recording tax, value added tax and any other similar tax or government charge applicable to the creation or redemption of any Basket made pursuant to this Agreement, regardless of whether or not such tax or charge is imposed directly on the Authorized Participant. To the extent the Trustee, the Sponsor or the Trust is required by law to pay any such tax or charge, the Authorized Participant agrees to promptly indemnify such party for any such payment, together with any applicable penalties, additions to tax or interest thereon.

  • 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.

  • Allocation of Taxable Income If any Fund delivers to its Auction Agent a notice in the form of Exhibit I to the Auction Agency Agreement designating all or a portion of any dividend on shares of any series of MuniPreferred of such Fund to consist of net capital gains or other income taxable for Federal income tax purposes, and BD is a Broker-Dealer for such series, such Auction Agent shall deliver such notice to BD on the Business Day following its receipt of such notice from such Fund. On or prior to the Auction Date referred to in such notice, BD will contact each of its customers that is a Beneficial Owner of shares of such series of MuniPreferred or a Potential Beneficial Owner of shares of such series of MuniPreferred interested in submitting an Order in the Auction to be held on such Auction Date, and BD will notify such Beneficial Owners and Potential Beneficial Owners of the contents of such notice. BD will be deemed to have notified such Beneficial Owners and Potential Beneficial Owners if, for each of them, (i) BD makes a reasonable effort to contact such Beneficial Owner or Potential Beneficial Owner by telephone, and (ii) upon failing to contact such Beneficial Owner or Potential Beneficial Owner by telephone BD mails written notification to such Beneficial Owner or Potential Beneficial Owner at the mailing address indicated in the account records of BD. The Auction Agent for any series of MuniPreferred shall be required to notify BD if it is a Broker-Dealer for such series within two Business Days after each Auction of such series that involves an allocation of income taxable for Federal income tax purposes as to the dollar amount per share of such taxable income and income exempt from Federal income taxation included in the related dividend.

  • 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.

  • Tax Computation For purposes of determining whether any of the Total Payments will be subject to the Excise Tax and the amounts of such Excise Tax:

  • 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,

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