General Method. Except as provided in Section 3.1(b), Tax Items of the Cal Dive Group Members shall be apportioned between Pre-IPO Periods and Post-IPO Periods in accordance with the principles of Treasury Regulations Section 1.1502-76(b) or an applicable corresponding provision under the Tax Laws of any state, local or foreign jurisdiction, as such corresponding provision is reasonably interpreted and applied by Parent. No election shall be made under Treasury Regulations Section 1.1502-76(b)(2)(ii) (relating to ratable allocation of a year’s items).
General Method. Except as provided in Section 3.1(b), in the case of any Straddle Period, Tax Items shall be apportioned between Pre-Deconsolidation Periods and Post-Deconsolidation Periods in accordance with the principles of Treasury Regulations Section 1.1502-76(b) or an applicable corresponding provision under the Tax Laws of any state, local or foreign jurisdiction, as such corresponding provision is reasonably interpreted and applied by Distributing. No election shall be made under Treasury Regulations Section 1.1502-76(b)(2)(ii) (relating to ratable allocation of a year’s items). If any applicable Deconsolidation Date is not an Accounting Cutoff Date, the principles of Treasury Regulations Section 1.1502-76(b)(2)(iii) will be applied to ratably allocate the Tax Items (other than extraordinary items) for the month which includes the applicable Deconsolidation Date.
General Method. In our proposed protocol, the first round is a clustering method that divides the entire set of nodes into subgroups based on the geometric locations of nodes. Each of these subgroups selects a leader (also called dominator). This selection process is done by generating a connected dominating set (CDS) [16], [17], [18], [19] from the set of wireless nodes. Once the CDS has been constructed, the set of dominators of the CDS form the subgroup leaders; each dominator and the set of its dominatees form an individual subgroup. We use the term subgroup leader and dominator interchangeably hereafter. We could apply the GDH.2 protocol (Algorithm 1) or some other key agreement protocols to the set of dominators and the key is generated as a contribution from all the dominators (and connectors). On suc- cess of the key agreement protocol over the dominators, each dominator and the set of its group members follow the key dis- tribution protocol if the same key for each subgroup is required. The afore mentioned steps make sure that all the nodes share the same key, and an overall key agreement is reached. We first outline our hybrid key agreement protocol that is suitable for wireless ad hoc networks.
1. Wireless nodes construct a CDS distributively.
2. The contributory key agreement protocol is applied among the set of computed dominators and connectors.
3. Each dominator distributes the computed key to all its dom- inatees if the same key is required. Otherwise, each subgroup performs its own key agreement protocol. Here we prefer the subgroup key be different from the key for backbone. This difference adds more freedom of managing the group members such as joining and leaving. The motiva- tion of using CDS is the presence of group leaders for efficient management of the group membership activities. In addition, using CDS will potentially save the communication cost as we will analyze later. It is critical to reduce communication costs in wireless ad hoc networks as the wireless nodes are often powered by batteries only. Although we will not elaborate in detail, we require that two nodes need authenticate each other when they want to com- municate with each other for key agreement. This will prevent some nodes outside of the group from impersonating the node in the group.
General Method. This chapter describes common experimental methods shared by each of the three subsequently described experiments (Chapters 3, 4, and 5).
General Method
