Common use of Carryovers or Carrybacks of Tax Benefits Clause in Contracts

Carryovers or Carrybacks of Tax Benefits. If any Tax Item allocable to the Splitco Business in a Tax Year is carried forward or back and utilized as a Tax Benefit in another Tax Year, then, except as provided in Section 2.2(k), the resulting Tax Benefit shall be allocated to Splitco. If any Tax Item allocable to the Distributing Business in a Tax Year is carried forward or back and utilized as a Tax Benefit in another Tax Year, the resulting Tax Benefit shall be allocated to Distributing.

Carryovers or Carrybacks of Tax Benefits. If any Tax Item allocable attributable to or arising from the Splitco Business in a Tax Year Period is carried forward or back and utilized as to generate a Tax Benefit in another Tax YearPeriod, then, except as provided in Section 2.2(k2.2(g), the resulting Tax Benefit shall be allocated to Splitco. If any Tax Item allocable attributable to or arising from the Distributing Business in a Tax Year Period is carried forward or back and utilized as to generate a Tax Benefit in another Tax YearPeriod, the resulting Tax Benefit shall be allocated to Distributing.