Apportionment of Earnings and Profits and Tax Attributes. (a) If the UTC Affiliated Group has a Tax Attribute, the portion, if any, of such Tax Attribute apportioned to a SpinCo or any member of a SpinCo Group and treated as a carryover to the first Post-Deconsolidation Period of such SpinCo (or such member) shall be determined by UTC in accordance with Treasury Regulations Sections 1.1502-21, 1.1502-21T, 1.1502-22, 1.1502-79 and, if applicable, 1.1502-79A.
Appears in 7 contracts
Samples: Tax Matters Agreement (Raytheon Technologies Corp), Tax Matters Agreement (Otis Worldwide Corp), Tax Matters Agreement (Carrier Global Corp)
