Apportionment of Earnings and Profits and Tax Attributes. (a) If the EPC Affiliated Group has a Tax Attribute, the portion, if any, of such Tax Attribute apportioned to SpinCo or the members of the SpinCo Group and treated as a carryover to the first Post-Distribution Taxable Period of SpinCo (or such member) shall be determined by EPC in accordance with Treasury Regulation Sections 1.1502-21, 1.1502-21T, 1.1502-22, 1.1502-79 and, if applicable, 1.1502-79A.
Appears in 3 contracts
Samples: Tax Matters Agreement, Tax Matters Agreement (Energizer SpinCo, Inc.), Tax Matters Agreement (Energizer SpinCo, Inc.)
Apportionment of Earnings and Profits and Tax Attributes. (a) If the EPC IAC Affiliated Group has a Tax Attribute, the portion, if any, of such Tax Attribute apportioned to SpinCo or the members any member of the SpinCo Group and treated as a carryover to the first Post-Distribution Taxable Deconsolidation Period of SpinCo (or such member) shall be determined by EPC IAC in accordance with Treasury Regulation Regulations Sections 1.1502-21, 1.1502-21T, 1.1502-22, 1.1502-79 and, if applicable, 1.1502-79A.
Appears in 2 contracts
Samples: Tax Matters Agreement (IAC/InterActiveCorp), Tax Matters Agreement (Vimeo, Inc.)
