Common use of Filing Claims for Carrybacks Clause in Contracts

Filing Claims for Carrybacks. If a Tax Item allocable to Splitco is carried back from a Tax Year beginning in the Post-Distribution Period and generates a Tax Benefit on a Combined Return filed with respect to a Tax Year beginning in the Pre-Distribution Period, then, upon the request of Splitco, Distributing may, in its reasonable discretion, file a claim for refund arising from such Tax Benefit. Any resulting Tax Benefit shall be allocated to Splitco pursuant to Section 2.2(j), except as otherwise provided by Section 2.2(k). For the avoidance of doubt, nothing in this Agreement imposes any obligation on Splitco to carry back any such Tax Items.

Appears in 5 contracts

Samples: Tax Sharing Agreement, Tax Sharing Agreement (Gci Liberty, Inc.), Tax Sharing Agreement (Liberty Interactive Corp)

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Filing Claims for Carrybacks. If a Tax Item allocable attributable to or arising from the Splitco is Business may be carried back from a Tax Year Period beginning in after the Post-Distribution Period and generates Date to generate a Tax Benefit on a Combined Return filed with respect to a Tax Year Period beginning in the Pre-Distribution Period, then, upon the request of Splitco, Distributing may, in its reasonable discretion, file a claim for refund arising from such Tax Benefit. Any resulting such Tax Benefit shall be allocated to Splitco pursuant to Section 2.2(j2.2(f), except as otherwise provided by Section 2.2(k2.2(g). For the avoidance of doubt, nothing in this Agreement imposes any obligation on Splitco to carry back any such Tax Items.

Appears in 4 contracts

Samples: Tax Sharing Agreement (Liberty Media Corp), Tax Sharing Agreement (Atlanta Braves Holdings, Inc.), Tax Sharing Agreement (Liberty Media Corp)

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Filing Claims for Carrybacks. If a Tax Item allocable to Splitco is carried back from a Tax Year beginning in the Post-Distribution Period and generates a Tax Benefit on a Combined Return filed with respect to a Tax Year beginning in the Pre-Distribution Period, then, upon the request of Splitco, Distributing may, in its reasonable sole discretion, file a claim for refund arising from such Tax Benefit. Any resulting Tax Benefit shall be allocated to Splitco pursuant to Section 2.2(j2.02(g), except as otherwise provided by Section 2.2(k2.02(h). For the avoidance of doubt, nothing in this Agreement imposes any obligation on Splitco to carry back any such Tax Items.

Appears in 3 contracts

Samples: Tax Sharing Agreement, Tax Sharing Agreement (Liberty Latin America Ltd.), Tax Sharing Agreement (Liberty Latin America Ltd.)

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