Common use of Allocation of Taxes for Separate Tax Returns Clause in Contracts

Allocation of Taxes for Separate Tax Returns. (A) The Company shall be allocated all Taxes reported, or required to be reported, on (x) a Company Separate Tax Return, (y) a SpinCo Separate Tax Return with respect to a Pre-Distribution Period or (z) any SpinCo Separate Tax Return or a Tax Return of a member of the Parent Group to the extent attributable to, resulting from or arising in connection with a Specified SpinCo Pre-Closing Tax Matter. (B) SpinCo shall be allocated all Taxes reported, or required to be reported, on a SpinCo Separate Tax Return with respect to a Post-Distribution Period, other than to the extent attributable to, resulting from or arising in connection with a Specified SpinCo Pre-Closing Tax Matter.

Appears in 5 contracts

Samples: Tax Matters Agreement (Westinghouse Air Brake Technologies Corp), Tax Matters Agreement (Westinghouse Air Brake Technologies Corp), Tax Matters Agreement (Transportation Systems Holdings Inc.)

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Allocation of Taxes for Separate Tax Returns. (A) The Company LMC shall be allocated all Taxes reported, or required to be reported, on (x) a Company LMC Separate Tax Return, (y) a SpinCo Spinco Separate Tax Return with respect to a Pre-Distribution Period or (z) any SpinCo a Spinco Separate Tax Return or a Tax Return of a member of the Parent Leidos Group to the extent attributable to, resulting from from, or arising in connection with a Specified SpinCo Spinco Pre-Closing Tax Matter. (B) SpinCo Spinco shall be allocated all Taxes reported, or required to be reported, on a SpinCo Spinco Separate Tax Return with respect to a Post-Distribution Period, other than to the extent Taxes attributable to, resulting from from, or arising in connection with a Specified SpinCo Spinco Pre-Closing Tax Matter.

Appears in 2 contracts

Samples: Tax Matters Agreement, Tax Matters Agreement (Leidos Holdings, Inc.)

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