Apportionment of Tax Attributes. (i) If the Parent Consolidated Group has a Tax Attribute, the portion, if any, of such Tax Attribute apportioned to SpinCo or any member of the SpinCo Consolidated Group and treated as a carryover to the first Post-Distribution Taxable Period of SpinCo (or such member) shall be determined by Parent 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 8 contracts
Samples: Tax Matters Agreement (Consensus Cloud Solutions, Inc.), Tax Sharing Agreement, Tax Sharing Agreement
Apportionment of Tax Attributes. (i) If the Parent Consolidated Group has a Tax Attribute, the portion, if any, of such Tax Attribute apportioned to SpinCo any Spinco or any member the members of the SpinCo its respective Spinco Consolidated Group and treated as a carryover to the first Post-Distribution Taxable Period of SpinCo such Spinco (or such member) shall be determined by Parent 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 5 contracts
Samples: Tax Sharing Agreement (HSN, Inc.), Tax Sharing Agreement (Ticketmaster), Tax Sharing Agreement (Tree.com, Inc.)
Apportionment of Tax Attributes. (i) If the Parent Consolidated Group has a Tax Attribute, the portion, if any, of such Tax Attribute apportioned to SpinCo or any other member of the SpinCo Consolidated Group and treated as a carryover to the first Post-Distribution Taxable Period of SpinCo (or such member) shall be determined by Parent in accordance with Treasury Regulation Sections 1.1502-9T, 1.1502-21, 1.1502-21T, 1.1502-22, 1.1502-79 and, if applicable, 1.1502l.1502-79A.
Appears in 3 contracts
Samples: Tax Sharing Agreement, Tax Sharing Agreement (Marathon Petroleum Corp), Tax Sharing Agreement (Marathon Petroleum Corp)
