Consistent Treatment. Unless and until there has been a Final Determination to the contrary, 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 payments between the Covidien Group and the Mallinckrodt Group as set forth in Article 5.05, (b) the Rulings, (c) the Tax Opinions, or (d) the Tax treatment of any transaction included in the Reorganization.
Appears in 4 contracts
Samples: Tax Matters Agreement (Covidien PLC), Tax Matters Agreement (Mallinckrodt PLC), Tax Matters Agreement (Mallinckrodt PLC)
Consistent Treatment. Unless and until there has been a Final Determination to the contrary, 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 allocation of payments Taxes between the Covidien Bentley Group and the Mallinckrodt CPEX Group as set forth in Article 5.05, this Agreement or (b) the Rulings, (c) Contribution Tax Treatment and the Distribution Tax Opinions, or (d) the Tax treatment of any transaction included in the ReorganizationTreatment.
Appears in 3 contracts
Samples: Tax Sharing Agreement (Bentley Pharmaceuticals Inc), Tax Sharing Agreement (CPEX Pharmaceuticals, Inc.), Tax Sharing Agreement (CPEX Pharmaceuticals, Inc.)
Consistent Treatment. Unless and until there has been a Final Determination to the contrary, 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 allocation of payments Taxes between the Covidien Myriad Group and the Mallinckrodt MPI Group as set forth in Article 5.05, this Agreement or (b) the Rulings, (c) Contribution Tax Treatment and the Distribution Tax Opinions, or (d) the Tax treatment of any transaction included in the ReorganizationTreatment.
Appears in 2 contracts
Samples: Tax Sharing Agreement (Myriad Pharmaceuticals, Inc.), Tax Sharing Agreement (Myriad Genetics Inc)
Consistent Treatment. Unless and until there has been a Final Determination to the contrary, 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 allocation of payments Taxes and Benefit Items between the Covidien ASD Group and the Mallinckrodt WABCO Group as set forth in Article 5.05this Agreement, (b) the RulingsRuling, (c) the Tax OpinionsOpinion, or (d) the Tax treatment of any transaction included in the ReorganizationReorganization agreed upon by the parties.
Appears in 2 contracts
Samples: Tax Sharing Agreement, Tax Sharing Agreement (WABCO Holdings Inc.)
Consistent Treatment. Unless and until there has been a Final Determination to the contrary, 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 allocation of payments Taxes and Tax Benefits between the Covidien Verizon Group and the Mallinckrodt Spinco Group as set forth in Article 5.05this Agreement, (b) the Rulings, Ruling or (c) the Tax Opinions, or (d) the Tax treatment of any transaction included in the ReorganizationOpinion.
Appears in 2 contracts
Samples: Tax Sharing Agreement (Idearc Inc.), Tax Sharing Agreement (Idearc Inc.)
Consistent Treatment. Unless and until there has been a Final Determination to the contrary, each Party agrees not to take any position on any Tax Return, in connection with any Tax Contest Claim or otherwise that is inconsistent with (a) the treatment allocation of payments Taxes between the Covidien DG Group and the Mallinckrodt SpinCo Group as set forth in Article 5.05, this Agreement or (b) the Rulings, (c) Contribution Tax Treatment and the Redemption Tax Opinions, or (d) the Tax treatment of any transaction included in the ReorganizationTreatment.
Appears in 2 contracts
Samples: Tax Matters Agreement (Sizmek Inc.), Tax Matters Agreement (New Online Co)
Consistent Treatment. Unless and until there has been a Final Determination to the contrary, 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 allocation of payments Taxes and Tax Deductions between the Covidien ASD Group and the Mallinckrodt WABCO Group as set forth in Article 5.05this Agreement, (b) the RulingsRuling, (c) the Tax OpinionsOpinion, or (d) the Tax treatment of any transaction included in the ReorganizationReorganization agreed upon by the parties.
Appears in 1 contract
