For U. S. Federal income Tax purposes, the taxable year of SpinCo will close as of the end of the Distribution Date. For any taxable period that includes (but does not end on) the Distribution Date (a “Straddle Period”), Taxes for the Pre-Distribution Tax Period shall be computed (i) in the case of Taxes imposed on a periodic basis (such as real, personal and intangible property Taxes), on a daily pro rata basis and (ii) in the case of other Taxes generally, as if the taxable period ended as of the close of business on the Distribution Date.
Appears in 4 contracts
Samples: Tax Matters Agreement (Synaptogenix, Inc.), Tax Matters Agreement (Neurotrope, Inc.), Tax Matters Agreement (Neurotrope Bioscience, Inc.)