Allocation of Taxes for Combined Returns. Distributing shall be allocated: (A) all Taxes that are attributable to members of the Distributing Group and reported on, or required to be reported on, a Combined Return; and (B) all Taxes that are attributable to members of the Spinco Group for the Pre-Distribution Period and reported on, or required to be reported on, a Combined Return. Spinco shall be allocated all Taxes that are attributable to members of the Spinco Group for the Post-Distribution Period and reported on, or required to be reported on, a Combined Return.
Appears in 7 contracts
Samples: Tax Sharing Agreement (CommerceHub, Inc.), Tax Sharing Agreement (CommerceHub, Inc.), Tax Sharing Agreement (Liberty Broadband Corp)
Allocation of Taxes for Combined Returns. Distributing shall be allocated: (A) all Taxes that are attributable to members of the Distributing Group and reported on, or required to be reported on, a Combined Return; and (B) all Taxes that are attributable to members of the Spinco Splitco Group for the Pre-Distribution Period and reported on, or required to be reported on, a Combined Return. Spinco Splitco shall be allocated all Taxes that are attributable to members of the Spinco Splitco Group for the Post-Distribution Period and reported on, or required to be reported on, a Combined Return.
Appears in 2 contracts
Samples: Tax Sharing Agreement (Liberty Interactive Corp), Tax Sharing Agreement (Liberty Expedia Holdings, Inc.)
