Apportionment of Tax Attributes. (a) Tax Attributes arising in a Pre-Distribution Period will be allocated to (and the benefits and burdens of such Tax Attributes will inure to) the members of the DDR Group and the members of the RVI Group in accordance with the Code, Treasury Regulations, and any other applicable Tax Law, and, in the absence of controlling legal authority or unless otherwise provided under this Agreement, Tax Attributes shall be allocated to the taxpayer that created such Tax Attributes.
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Samples: Tax Matters Agreement (Retail Value Inc.), Tax Matters Agreement (Retail Value Inc.)
Apportionment of Tax Attributes. (a) Tax Attributes arising in a Pre-Distribution Tax Period will be allocated to (and the benefits and burdens of such Tax Attributes will inure to) the members of the DDR Company Group and the members of the RVI BTC Group in accordance with the Code, Treasury Regulations, and any other applicable Tax Law, and, in the absence of controlling legal authority or unless otherwise provided under this Agreement, Tax Attributes shall be allocated to the taxpayer that created such Tax Attributes.
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Samples: Agreement and Plan of Merger (Industrial Property Trust Inc.), Agreement and Plan of Merger (Prologis, L.P.)
Apportionment of Tax Attributes. (a) Tax Attributes arising in a Pre-Distribution Period will be allocated to (and the benefits and burdens of such Tax Attributes will inure to) the members of the DDR Realty Income Group and the members of the RVI Orion Group in accordance with the Code, Treasury Regulations, and any other applicable Tax Law, and, in the absence of controlling legal authority or unless otherwise provided under this Agreement, Tax Attributes shall be allocated to the taxpayer legal entity that created such Tax Attributes.
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