Apportionment of Earnings and Profits and Tax Attributes. (a) If the Old Xxxxxxx Controls Affiliated Group has a Tax Attribute, the portion, if any, of such Tax Attribute required to be apportioned to Adient or the members of the Adient Group and treated as a carryover to the first Post-Distribution Period of Adient (or such member) shall be determined in good faith by Xxxxxxx Controls 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 6 contracts
Samples: Tax Matters Agreement, Tax Matters Agreement (Adient PLC), Tax Matters Agreement (Adient LTD)
