Correlative Adjustment. If as a result of a Final Determination, a Party or its Affiliate becomes entitled to an increase of an item of deduction, loss, or credit (or a reduction of an item of income or gain) that is included in a Pre-Distribution Tax Period or the portion of a Straddle Tax Period ending on the Distribution Date, and another Party or its Affiliate suffers a correlative disallowance of an item of deduction, loss or credit (or an increase of an item of income or gain) that is included in a Pre-Distribution Tax Period or the portion of a Straddle Tax Period ending on the Distribution Date, the former Party shall pay any amount it actually realizes as a result of the Tax benefit to the latter Party, but only to the extent of the latter Party’s detriment.
Correlative Adjustment. 3 1.13 Disputed Adjustment 3 1.14 Distribution Date 3 1.15 Federal Tax Allocation Agreement 3 1.16 Final Determination 3 1.17 Independent Third Party 4 1.18 Indemnified Party 4 1.19 Indemnifying Party 4 1.20 Initial Determination 4 1.21 Interested Party 4 1.22 Interested Party Notice 4 1.23 Lucent Tax Adjustment 4 1.24 Lucent Tax Benefit 4 1.25 Net Tax Liability Payable 4 1.26 Net Tax Refund Receivable 5 1.27 Non-Line of Business Adjustment 5 1.28 Restructuring Adjustment 5 1.29 Restructuring Tax 5 1.30 Restructuring Transaction 5 1.31 Return 5 1.32 Ruling 5 1.33 Ruling Documents 5 1.34 Separate Return 5 1.35 Separation and Distribution Agreement 6 1.36 Service 6 1.37 Significant Obligation 6 1.38 State and Local Income Tax Allocation Agreement 6 1.39 Supplemental Ruling 6 1.40 Supplemental Ruling Documents 6 1.41 Tax 6
