Common use of Ameriprise and AXP Issues Clause in Contracts

Ameriprise and AXP Issues. AXP and Ameriprise hereby agree that during the course of the audit of any Affiliation Year, they will in good faith endeavor to discuss and resolve separately with the IRS district agents any "Ameriprise Issues" and "AXP Issues" (defined below). "Ameriprise Issues" are issues relating to items of income, gain, loss, deduction, or Credit that are attributable solely to the Ameriprise Group and that could not reasonably have material adverse consequences for the U.S. federal income Tax liability of a member of the AXP Group (other than a member of the Ameriprise Group) if resolved against the taxpayer, as determined in good faith by AXP. "AXP Issues" are any other issues, including issues relating to Foreign Attributes of the Ameriprise Group.

Ameriprise and AXP Issues. AXP and Ameriprise hereby agree that during the course of the audit of any Affiliation Year, they will in good faith endeavor to discuss and resolve separately with the IRS district agents any "‘‘Ameriprise Issues" ’’ and "‘‘AXP Issues" ’’ (defined below). "‘‘Ameriprise Issues" ’’ are issues relating to items of income, gain, loss, deduction, or Credit that are attributable solely to the Ameriprise Group and that could not reasonably have material adverse consequences for the U.S. federal income Tax liability of a member of the AXP Group (other than a member of the Ameriprise Group) if resolved against the taxpayer, as determined in good faith by AXP. "‘‘AXP Issues" ’’ are any other issues, including issues relating to Foreign Attributes of the Ameriprise Group.