Characterization of and Adjustments to Payments. (a) For all Tax purposes, Cogint and SpinCo shall treat any payment by Cogint to a member of the Spinco Group or by Spinco to a member of the Cogint Group required by this Agreement (other than payments with respect to interest accruing after the Distribution Date) as either a contribution by Cogint to SpinCo or a distribution by SpinCo to Cogint, as the case may be, occurring immediately prior to the Distribution.
Appears in 4 contracts
Samples: Tax Matters Agreement, Tax Matters Agreement (Cogint, Inc.), Tax Matters Agreement (Red Violet, Inc.)
