Allocation of Separation-Related Taxes. If the Spin-Off occurs: (a) No-Fault. Income Taxes attributable to a Tax-Free Transaction Failure, to the extent not allocated pursuant to Sections 2.05(b), (c) or (d), shall be allocated to the EFH Parties.
Appears in 5 contracts
Samples: Tax Matters Agreement (Vistra Energy Corp), Tax Matters Agreement (Vistra Energy Corp), Tax Matters Agreement (Energy Future Competitive Holdings Co LLC)