Consolidated Returns. CAC, the Seller and the Issuer are members of an affiliated group within the meaning of Section 1504 of the Internal Revenue Code which will file a consolidated federal income tax return at all times until the termination of the Basic Documents.
Consolidated Returns. The Originator, the Seller and the Issuer will file a consolidated federal income tax return at all times until the termination of the Basic Documents.
Consolidated Returns. The Contributor, the Depositor and the Issuer are members of an affiliated group within the meaning of Section 1504 of the Internal Revenue Code which will file a consolidated federal income tax return at all times until termination of the Transaction Documents.
Consolidated Returns. Company will not, nor will it permit any of its Subsidiaries to, file or consent to the filing of any consolidated income tax return with any Person (other than Holdings or any of its Subsidiaries).
Consolidated Returns. Ashland Global shall prepare and timely file (or cause to be prepared and timely filed) each Federal income Tax Return required to be filed on behalf of the Ashland Global Consolidated Group (an “Ashland Global Consolidated Return”). Ashland Global shall include the Valvoline Consolidated Group in such Tax Return if entitled to do so.
Consolidated Returns. Select shall prepare and timely file (or cause to be prepared and timely filed) each U.S. Federal income Tax Return required to be filed on behalf of the Select Consolidated Group (a “Select Consolidated Return”). Select shall include the Concentra Consolidated Group in such Tax Return if entitled to do so under applicable Law.
Consolidated Returns. SpinCo and TRSCo will be part of the U.S. federal income tax consolidated group of which Lennar is the common parent until the end of the Distribution Date, and all parties will file their U.S. federal income tax returns consistent with that treatment.
Consolidated Returns. J&J shall prepare and timely file (or cause to be prepared and timely filed) each U.S. Federal income Tax Return required to be filed on behalf of the J&J Consolidated Group (a “J&J Consolidated Return”). J&J shall include the Kenvue Consolidated Group in such Tax Return if entitled to do so under applicable Law.
Consolidated Returns. Seller shall prepare (or cause to be prepared) and timely file all consolidated United States Income Tax Returns (within the meaning of Section 1501 of the Code and the Treasury Regulations promulgated pursuant to Section 1502 of the Code) and all other combined, joint, consolidated or unitary Tax Returns required to be filed with any Tax Authority (collectively the "Consolidated Returns") with respect to the Company for any Tax Period including, or ending on or before, the Closing Date. Payment of Taxes shown to be due on such Consolidated Returns shall be made in accordance with Section 8.6 hereof. In a manner consistent with past custom and practice of Seller and the Company, Purchaser shall timely provide (or cause to be provided) to the Seller all information (including pro forma Tax Returns, schedules, statements and supporting documentation) reasonably required in connection with the preparation and filing of such Consolidated Returns. Seller shall not elect, pursuant to Treasury Regulation Section 1.1502-20(g) or Treasury Regulation Section 1.1502-96(d), or any comparable provision of law or regulations, to reattribute to itself any portion of the net operating loss carryovers, net capital loss carryovers or section 382 limitation, if any, attributable to the Company. Any consolidated section 382 limitation applicable to the Seller and its subsidiaries (including the Company) as of the Closing Date, if any, shall be apportioned between the Seller and its subsidiaries (other than the Company), on the one hand, and the Company, on the other, pursuant to Treasury Regulation Section 1.1502-95 based on the relative fair market value of such entities immediately prior to the Closing Date. Any such allocation shall be proposed by the Seller for approval by the Purchaser, which approval shall not be unreasonably withheld.
Consolidated Returns. (a) Parent shall be responsible for the preparation and filing of all Consolidated Returns; provided, however, that Sub shall have the right to review, at least 10 days prior to the Return Due Date of any Consolidated Return, a draft of the portion of such Return that reflects the operations and tax items of the Sub Group.
(b) Parent shall be responsible for the payment of all Federal Income Taxes attributable to Consolidated Return Years, and shall be entitled to all Federal Income Tax refunds attributable to Consolidated Return Years.