Common use of Allocation of Consolidated Tax Liability for Earnings and Profits Purposes Clause in Contracts

Allocation of Consolidated Tax Liability for Earnings and Profits Purposes. With respect to the determination of earnings and profits for federal income tax purposes (as described under Treasury Regulation Section 1.1502-33(d)), the Present Subsidiaries shall have allocated to them that portion of the Consolidated Tax Liability determined in accordance with the method set forth in Code Section 1552(a)(1) and Treasury Regulation Section 1.1552-1(a)(1), all as required under Treasury Regulation Section 1.1552-1(c)(1).

Appears in 2 contracts

Samples: Tax Allocation Agreement (Enron Corp/Or/), Tax Allocation Agreement (Enron Corp/Or/)

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Allocation of Consolidated Tax Liability for Earnings and Profits Purposes. With respect to the determination of earnings and profits for federal income tax purposes (as described under Treasury Regulation Section 1.1502-33(d1.1502.33(d)), the Present Subsidiaries shall have allocated to them that portion of the Consolidated Tax Liability determined in accordance with the method set forth in Code Section 1552(a)(1) and Treasury Regulation Section 1.1552-1(a)(1), all as required under Treasury Regulation Section 1.1552-1(c)(1).

Appears in 1 contract

Samples: Tax Allocation Agreement (Enron Corp/Or/)

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Allocation of Consolidated Tax Liability for Earnings and Profits Purposes. With respect to the determination of earnings and profits for federal income tax purposes (as described under Treasury Regulation Regulations Section 1.1502-33(d1.1502.33(d)), the Present Subsidiaries Members shall have allocated to them that portion of the Consolidated Tax Liability determined in accordance with the method set forth in Code Section 1552(a)(1) and Treasury Regulation Regulations Section 1.1552-1(a)(1), all as required under Treasury Regulation Regulations Section 1.1552-1(c)(11.1552(c)(1).. PAYMENTS; CARRYBACKS/CARRYFORWARDS

Appears in 1 contract

Samples: Tax Allocation Agreement

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