General Method of Proration for Straddle Periods. In the case of any Straddle Period, Tax Items shall be apportioned between Pre-Distribution Periods and Post-Distribution Periods in accordance with the principles of Treasury Regulations Section 1.1502-76(b) and any other applicable Tax Law as reasonably interpreted and applied by EQT in its sole and absolute discretion. No election shall be made under Treasury Regulations Section 1.1502-76(b)(2)(ii) (relating to ratable allocation of a year’s Tax Items). If the External Distribution Date is not an Accounting Cutoff Date, the provisions of Treasury Regulations Section 1.1502-76(b)(2)(iii) will be applied to ratably allocate the items (other than extraordinary items) for the month which includes the External Distribution Date.
Appears in 4 contracts
Samples: Tax Matters Agreement (Equitrans Midstream Corp), Tax Matters Agreement (EQT Corp), Tax Matters Agreement (Equitrans Midstream Corp)
