ALLOCATION OF TAXES OF FOREIGN SUBSIDIARIES. If any foreign affiliate of Adaptec engaged in the software products business is required to join in the filing of a consolidated, combined, or unitary return for a period beginning before the Distribution Date with at least one affiliate of Adaptec that is not engaged in the software products business, the allocation of tax liability between those corporations shall be made by applying principles similar to those adopted by this Agreement. The parties agree to apply consistent allocation methods in allocating the earnings and profits of AMS between AMS and RCI pursuant to section 1.312-10(a) of the Treasury regulations.
Appears in 4 contracts
Samples: Tax Sharing Agreement (Roxio Inc), Tax Sharing Agreement (Roxio Inc), Tax Sharing Agreement (Roxio Inc)
