General Allocation of Taxes. (a) Income Tax Allocation to SnackCo. SnackCo shall be liable for (i) all U.S. Federal Income Taxes attributable to any Pre-Distribution Period that are imposed on any member of the SnackCo Pre-Distribution Group, including but not limited to joint and several liability under Treasury Regulation Section 1.1502-6, (ii) all Non-Canadian Foreign Income Taxes attributable to any Pre-Distribution Period that are imposed on any member of the SnackCo Pre-Distribution Group, (iii) all Income Taxes attributable to any Post-Distribution Period that are imposed on any member of the SnackCo Post-Distribution Group other than SnackCo Canada and (iv) any Residual Indemnity Obligations that relate to U.S. Federal Income Taxes or Non-Canadian Foreign Income Taxes.
Appears in 3 contracts
Samples: Sharing and Indemnity Agreement, Tax Sharing and Indemnity Agreement (Kraft Foods Group, Inc.), Tax Sharing and Indemnity Agreement (Kraft Foods Group, Inc.)
General Allocation of Taxes. (a) Income Tax Allocation to SnackCo. SnackCo shall be liable for (i) all U.S. Federal Income Taxes attributable to any Pre-Distribution Period that are imposed on any member of the SnackCo Pre-Distribution Group, including but not limited to joint and several liability under Treasury Regulation Section 1.1502-6, (ii) all Non-Canadian Foreign Income Taxes attributable to any Pre-Distribution Period that are imposed on any member of the SnackCo Pre-Distribution Group, (iii) all Income Taxes attributable to any Post-Distribution Period that are imposed on any member of the SnackCo Post-Distribution Group other than SnackCo Canada Canada, and (iv) any Residual Indemnity Obligations that relate to U.S. Federal Income Taxes or Non-Canadian Foreign Income Taxes.
Appears in 1 contract
Samples: Tax Sharing and Indemnity Agreement (Kraft Foods Group, Inc.)
