Characterization of and Adjustments to Payments. (a) For all Tax purposes, Parent and New BBX Capital shall treat any payment by Parent to a member of the New BBX Capital Group or by New BBX Capital to a member of the Parent Group required by this Agreement (other than payments with respect to interest accruing after the Distribution Date) as either a contribution by Parent to New BBX Capital or a distribution by New BBX Capital to Parent, as the case may be, occurring immediately prior to the Distribution.
Appears in 5 contracts
Samples: Tax Matters Agreement (BBX Capital Florida LLC), Tax Matters Agreement (BBX Capital Corp), Tax Matters Agreement (BBX Capital Florida LLC)