Common use of Exception for Certain Excluded Tax Assets Clause in Contracts

Exception for Certain Excluded Tax Assets. Any Tax Asset not included in a Tax Return by reason of Sections 163(j) or 267 of the Code, Treasury Regulations Section 1.1502-13 or any similar deferral provision under federal, state or foreign Tax Law shall be considered included in such Tax Return.

Exception for Certain Excluded Tax Assets. Any Tax Asset not included in a Tax Return by reason of Sections 163(j) or 267 of the Code, Treasury Regulations Section 1.1502-13 or any similar deferral provision under federal, state or foreign Tax Law shall be considered included in such Tax Return. This provision does not apply to any Tax Asset relating to Transocean stock options.