Filing Claims for Carrybacks. If a Tax Item allocable to Controlled 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 Controlled, Distributing may, in its sole discretion, file a claim for refund arising from such Tax Benefit. Any resulting Tax Benefit shall be allocated to Controlled pursuant to Section 2.2(f), except as otherwise provided by Section 2.2(g).
Appears in 4 contracts
Samples: Tax Sharing Agreement (Liberty Media Corp), Tax Sharing Agreement (Liberty Splitco, Inc.), Tax Sharing Agreement (Liberty Splitco, Inc.)
