EFFECTIVE TIME OF TRANSACTION. Conexant and Alpha agree that any transaction that, pursuant to the Distribution Agreement, is expressly effective immediately after the Time of Distribution shall be treated for federal Income Tax purposes as occurring at the beginning of the day following the Distribution Date.
Appears in 3 contracts
Samples: Tax Allocation Agreement (Skyworks Solutions Inc), Tax Allocation Agreement (Alpha Industries Inc), Tax Allocation Agreement (Conexant Systems Inc)
EFFECTIVE TIME OF TRANSACTION. Conexant and Alpha Mindspeed agree that any transaction that, pursuant to the Distribution Agreement, is expressly effective immediately after the Time of Distribution shall be treated for federal Income Tax purposes as occurring at the beginning of the day following the Distribution Date.
Appears in 2 contracts
Samples: Tax Allocation Agreement (Mindspeed Technologies Inc), Tax Allocation Agreement (Mindspeed Technologies Inc)
