Characterization. Any payment (other than interest thereon) made hereunder shall be treated by all parties for all purposes as a nontaxable intercompany settlement of liabilities existing immediately before the Distribution or, to the extent appropriate, as a non-taxable dividend distribution or capital contribution.
Appears in 18 contracts
Samples: Tax Sharing Agreement (LTC Healthcare Inc), Tax Sharing Agreement (Excel Legacy Corp), Tax Sharing Agreement (Pricesmart Inc)
