Common use of Consistent Treatment Clause in Contracts

Consistent Treatment. Unless and until there has been a Final Determination to the contrary, except as expressly and specifically provided otherwise in this Agreement, each Party agrees not to take any position on any Tax Return, in connection with any Tax Contest or otherwise that is inconsistent with (a) the treatment of liabilities and payments as set forth in Section 5.4, (b) the Tax Materials, (c) the Tax-Free Status of the Transactions or the Tax Treatment of the Transactions or (d) any other tax treatment set forth in this Agreement.

Consistent Treatment. Unless and until there has been a Final Determination to the contrary, except as expressly and specifically provided otherwise in this Agreement, each Party agrees not to take any position on any Tax Return, in connection with any Tax Contest or otherwise that is inconsistent with (a) the treatment of liabilities payments between the ▇▇▇▇▇▇▇ Group and payments the Fortive Group as set forth in Section Article 5.4, (b) the Tax MaterialsOpinions, or (c) the Tax-Free Status Tax treatment of any transaction included in the Transactions or the Tax Treatment of the Transactions or (d) any other tax treatment set forth in this AgreementReorganization.

Consistent Treatment. Unless and until there has been a Final Determination to the contrary, except as expressly and specifically provided otherwise in this Agreement, each Party agrees not to take any position on any Tax Return, in connection with any Tax Contest or otherwise that is inconsistent with (a) the treatment of liabilities payments between the Cummins Group and payments the Filtration Group as set forth in Section 5.4, or (b) the Tax Materials, (c) the Tax-Free Status of the Transactions or the Tax Treatment of the Transactions or (d) any other tax treatment set forth in this AgreementTransactions.