Effectiveness; Termination and Survival. This Agreement shall become effective upon the consummation of the Distribution. All rights and obligations arising hereunder with respect to a Pre-Distribution Tax Period shall survive until they are fully effectuated or performed. Notwithstanding anything in this Agreement to the contrary, this Agreement shall remain in effect and its provisions shall survive for the full period of all applicable statutes of limitation (giving effect to any extension, waiver or mitigation thereof).
Appears in 5 contracts
Samples: Tax Separation Agreement (Too Inc), Tax Separation Agreement (Too Inc), Tax Separation Agreement (Pitney Bowes Office Systems Inc)
Effectiveness; Termination and Survival. This Agreement shall become effective upon the consummation of the Distribution. All rights and obligations arising hereunder with respect to a Pre-Distribution Tax Period shall survive until they are fully effectuated or performed. Notwithstanding performed and, provided, further, that notwithstanding anything in this Agreement to the contrary, this Agreement shall remain in effect and its provisions shall survive for one year after the full period of all applicable statutes of limitation (giving effect to any extension, waiver or mitigation thereof)) and, with respect to any claim hereunder initiated prior to the end of such period, until such claim has been satisfied or otherwise resolved.
Appears in 5 contracts
Samples: Tax Separation Agreement (Tricon Global Restaurants Inc), Tax Separation Agreement (Tricon Global Restaurants Inc), Tax Separation Agreement (Tricon Global Restaurants Inc)
Effectiveness; Termination and Survival. This Agreement shall become effective upon the consummation of the Distribution. All rights and obligations arising hereunder with respect to a Pre-Distribution Tax Period shall survive until they are fully effectuated or performed. Notwithstanding performed and, provided, further, that notwithstanding anything in this Agreement to the contrary, this Agreement shall remain in effect and its provisions shall survive for the full period of all applicable statutes of limitation (giving effect to any extension, waiver or mitigation thereof).
Appears in 2 contracts
Samples: Tax Disaffiliation Agreement (Abercrombie & Fitch Co /De/), Tax Disaffiliation Agreement (Abercrombie & Fitch Co /De/)
Effectiveness; Termination and Survival. This Agreement shall become effective upon the consummation of the DistributionOffering. All rights and obligations arising hereunder with respect to a Pre-Distribution Offering Tax Period shall survive until they are fully effectuated or performed. Notwithstanding performed and, provided, further, that notwithstanding anything in this Agreement to the contrary, this Agreement shall remain in effect and its provisions shall survive for the full period of all applicable statutes of limitation (giving effect to any extension, waiver or mitigation thereof).
Appears in 1 contract
Effectiveness; Termination and Survival. This Agreement shall become effective upon the consummation of the Distributionexecution. All rights and obligations arising hereunder with respect to a Pre-Distribution Deconsolidation Tax Period shall survive until they are fully effectuated or performed. Notwithstanding anything in this Agreement to the contrary, this Agreement shall remain in effect and its provisions shall survive for the full period of all applicable statutes of limitation (giving effect to any extension, waiver or mitigation thereof).
Appears in 1 contract
Samples: Tax Indemnification Agreement (Nuvera Fuel Cells Inc)