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 Xxxxxxx Group and the Envista Group as set forth in Section 5.4, or (b) the Tax-Free Status of the Transactions.
Appears in 2 contracts
Samples: Tax Matters Agreement (Envista Holdings Corp), Tax Matters Agreement (Envista Holdings Corp)
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, Return in connection with any Tax Contest or otherwise that is inconsistent with (a) the treatment allocation of payments Taxes between the Xxxxxxx PPD Group and the Envista Furiex Group as set forth in Section 5.4, this Agreement or (b) the Tax-Free Status of Contribution Tax Treatment and the TransactionsDistribution Tax Treatment.
Appears in 2 contracts
Samples: Tax Sharing Agreement (Furiex Pharmaceuticals, Inc.), Tax Sharing Agreement (Furiex 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 of payments between the Xxxxxxx Cummins Group and the Envista Filtration Group as set forth in Section 5.4, or (b) the Tax-Free Status of the Transactions.
Appears in 2 contracts
Samples: Tax Matters Agreement (Atmus Filtration Technologies Inc.), Tax Matters Agreement (Atmus Filtration Technologies 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 of payments between the Xxxxxxx XXXXXXX Group and the Envista Fortive Group as set forth in Section Article 5.4, or (b) the Tax-Free Status Tax Opinions, or (c) the Tax treatment of any transaction included in the Transactions.Reorganization. RETENTION OF RECORDS; ACCESS
Appears in 1 contract
Samples: Tax Matters Agreement (Fortive Corp)
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 Xxxxxxx XXXXXXX Group and the Envista Fortive Group as set forth in Section Article 5.4, or (b) the Tax-Free Status Tax Opinions, or (c) the Tax treatment of any transaction included in the TransactionsReorganization.
Appears in 1 contract
Samples: Tax Matters Agreement
