Allocation of Tax Relating to Separate Returns. (i) Parent shall be responsible for any and all Foreign Income Taxes due with respect to or required to be reported on any Parent Separate Return (including any increase in such Foreign Income Tax as a result of a Final Determination); (ii) SpinCo shall be responsible for any and all Foreign Income Taxes due with respect to or required to be reported on any SpinCo Separate Return (including any increase in such Foreign Income Tax as a result of a Final Determination).
Allocation of Tax Relating to Separate Returns. (i) Distributing shall be responsible for any and all Foreign Income Taxes due with respect to or required to be reported on any Distributing Separate Return, including Foreign Income Tax of Distributing or any member of the Distributing Group imposed by way of withholding by a member of the SpinCo Group (and including any increase in such Foreign Income Tax as a result of a Final Determination); (ii) For the Tax Periods ending after the Deconsolidation Date, SpinCo shall be responsible for any and all Foreign Income Taxes due with respect to or required to be reported on any SpinCo Separate Return, including Foreign Income Tax of SpinCo or any member of the SpinCo Group imposed by way of withholding by a member of the Distributing Group (and including any increase in such Foreign Income Tax as a result of a Final Determination).
Allocation of Tax Relating to Separate Returns. (i) Ironwood shall be responsible for any and all Taxes for (A) Complete Pre-Distribution Periods due with respect to or required to be reported on any Cyclerion Separate Return and (B) all Tax Periods due with respect to or required to be reported on any Ironwood Separate Return (including, in each case, any increase in such Tax as a result of a Final Determination).
(ii) Cyclerion shall be responsible for any and all Taxes due with respect to or required to be reported on any Cyclerion Separate Return for (A) Pre-Distribution Periods (other than Complete Pre-Distribution Periods) and (B) Post-Distribution Periods (including, in each case, any increase in such Tax as a result of a Final Determination).
Allocation of Tax Relating to Separate Returns. (i) Valero shall be responsible for any and all State Income Taxes due with respect to or required to be reported on any Valero Separate Return (including any increase in such Tax as a result of a Final Determination); (ii) Corner Store shall be responsible for any and all State Income Taxes due with respect to or required to be reported on any Corner Store Separate Return (including any increase in such Tax as a result of a Final Determination).
Allocation of Tax Relating to Separate Returns. (i) Valero shall be responsible for any and all Foreign Income Taxes due with respect to or required to be reported on any Valero Separate Return, including Foreign Income Tax of Valero or any member of the Valero Group imposed by way of withholding by a member of the Corner Store Group (and including any increase in such Foreign Income Tax as a result of a Final Determination); (ii) Corner Store shall be responsible for any and all Foreign Income Taxes due with respect to or required to be reported on any Corner Store Separate Return, including Foreign Income Tax of Corner Store or any member of the Corner Store Group imposed by way of withholding by a member of the Valero Group (and including any increase in such Foreign Income Tax as a result of a Final Determination).
Allocation of Tax Relating to Separate Returns. (i) MINC shall be responsible for any and all State Income Taxes due with respect to or required to be reported on any MINC Separate Return (including any increase in such Tax as a result of a Final Determination); (ii) Freescale shall be responsible for any and all State Income Taxes due with respect to or required to be reported on any Freescale Separate Return (including any increase in such Tax as a result of a Final Determination).
Allocation of Tax Relating to Separate Returns. (i) bluebird shall be responsible for any and all Taxes for (A) Complete Pre-Distribution Periods due with respect to or required to be reported on any 2seventy Separate Return and (B) all Tax Periods due with respect to or required to be reported on any bluebird Separate Return (including, in each case, any increase in such Tax as a result of a Final Determination).
(ii) 2seventy shall be responsible for any and all Taxes due with respect to or required to be reported on any 2seventy Separate Return for (A) Pre-Distribution Periods (other than Complete Pre-Distribution Periods) and (B) Post-Distribution Periods (including, in each case, any increase in such Tax as a result of a Final Determination).
Allocation of Tax Relating to Separate Returns. (i) Biogen shall be responsible for any and all Taxes for (A) Complete Pre-Distribution Periods due with respect to or required to be reported on any Bioverativ Separate Return and (B) all Tax Periods due with respect to or required to be reported on any Biogen Separate Return (including, in each case, any increase in such Tax as a result of a Final Determination).
(ii) Bioverativ shall be responsible for any and all Taxes due with respect to or required to be reported on any Bioverativ Separate Return for (A) Pre-Distribution Periods (other than (i) Complete Pre-Distribution Periods and (ii) Taxes for any Bioverativ Separate Return for a Pre-Distribution Period that are equal to or in excess of $100,000, for which Biogen shall be responsible) and (B) Post-Distribution Periods (including, in each case, any increase in such Tax as a result of a Final Determination).
Allocation of Tax Relating to Separate Returns. (i) Alkermes shall be responsible for any and all Taxes for (A) Complete Pre-Distribution Periods due with respect to or required to be reported on any Mural Separate Return and (B) all Tax Periods due with respect to or required to be reported on any Alkermes Separate Return (including, in each case, any increase in such Tax as a result of a Final Determination).
(ii) Mural shall be responsible for any and all Taxes due with respect to or required to be reported on any Mural Separate Return for (A) Pre-Distribution Periods (other than Complete Pre-Distribution Periods) and (B) Post-Distribution Periods (including, in each case, any increase in such Tax as a result of a Final Determination).
Allocation of Tax Relating to Separate Returns. (i) EPC shall be responsible for any and all Foreign Taxes due with respect to or required to be reported on any EPC Separate Return (and including any increase in such Foreign Tax as a result of a Final Determination); (ii) SpinCo shall be responsible for any and all Foreign Taxes due with respect to or required to be reported on any SpinCo Separate Return (and including any increase in such Foreign Tax as a result of a Final Determination).
