Allocation of Earnings and Profits. FOR TAXABLE PERIODS ENDING BEFORE OR INCLUDING THE EFFECTIVE DATE. All earnings and profits of the Consolidated Group for all Taxable Periods ending before or including the Effective Date shall be allocated pursuant to Section 1552 of the Code among the members of the Consolidated Group in accordance with the ratio which that portion of the consolidated taxable income attributable to each member of the Consolidated Group having taxable income bears to the consolidated taxable income of the Consolidated Group in accordance with Section 1552(a)(1) of the Code and the Regulations thereunder.
Appears in 4 contracts
Samples: Tax Sharing and Indemnity Agreement (Demandstar Com Inc), Tax Indemnity Agreement (Zapata Corp), Tax Sharing and Indemnity Agreement (Zap Com Corp)
