Filing and Payment Responsibility. (a) Each of HRPT (on behalf of the HRPT Group) and GOV (on behalf of the GOV Group) shall cause to be prepared and filed such Tax Returns as the HRPT Group and the GOV Group, respectively, are required to file with applicable Taxing Authorities. Each of HRPT (on behalf of the HRPT Group) and GOV (on behalf of the GOV Group) agree that, except as required by applicable law or a final determination resulting from a Tax Contest (defined below) including either HRPT or GOV, they will not take positions in any such Tax Return that are inconsistent with (i) the description of federal Income Tax consequences in the GOV Registration Statement or in a report on Form 8-K to be filed by HRPT with the Securities and Exchange Commission on or immediately after the Effective Date and (ii) and any other Tax Return, whether filed on behalf of the HRPT Group or the GOV Group, previously or substantially contemporaneously filed with such Tax Return. In particular, HRPT and GOV will use all reasonable business efforts to cooperate with one another in valuing the individual assets comprising the Property Assets, to the extent such valuations are necessary for Tax purposes.
Appears in 4 contracts
Samples: Transaction Agreement (Government Properties Income Trust), Transaction Agreement (Government Properties Income Trust), Transaction Agreement (Government Properties Income Trust)
