Closing Agreement. At Ameriprise's request, at Ameriprise's sole cost and expense, AXP will cooperate in good faith in an effort to enter into a closing agreement with the IRS of the type described in Treasury Regulations Section 1.1503-2(g)(2)(iv)(B)(2), to the effect that Dual Consolidated Losses will not be recaptured as a result of the Distribution. ARTICLE VII
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Samples: Tax Allocation Agreement (Ameriprise Financial Inc), Tax Allocation Agreement (Ameriprise Financial Inc)
Closing Agreement. At Ameriprise's request, at Ameriprise's sole cost and expense, AXP will cooperate in good faith in an effort to enter into a closing agreement with the IRS of the type described in Treasury Regulations Section 1.1503-2(g)(2)(iv)(B)(2), to the effect that Dual Consolidated Losses will not be recaptured as a result of the Distribution. ARTICLE VII.
Appears in 1 contract
Closing Agreement. At Ameriprise's ’s request, at Ameriprise's ’s sole cost and expense, AXP will cooperate in good faith in an effort to enter into a closing agreement with the IRS of the type described in Treasury Regulations Section 1.1503-2(g)(2)(iv)(B)(2), to the effect that Dual Consolidated Losses will not be recaptured as a result of the Distribution. ARTICLE VII.
Appears in 1 contract
Samples: Tax Allocation Agreement