General Method of Proration. 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 Regulation Section 1.1502-76(b) as reasonably interpreted and applied by the Companies. No election shall be made under Treasury Regulation Section 1.1502-76(b)(2)(ii) (relating to ratable allocation of a year’s items). If the Deconsolidation Date is not an Accounting Cutoff Date, the provisions of Treasury Regulation 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 Deconsolidation Date.
Appears in 9 contracts
Samples: Tax Matters Agreement, Tax Sharing Agreement, Tax Matters Agreement (CST Brands, Inc.)
General Method of Proration. In the case of any Straddle Period, Tax Items shall be apportioned between Pre-Deconsolidation Distribution Periods and Post-Deconsolidation Post- Distribution Periods in accordance with the principles of Treasury Regulation Section 1.1502-76(b) as reasonably interpreted and applied by the Companies. No election shall be made under Treasury Regulation Section 1.1502-1.1502- 76(b)(2)(ii) (relating to ratable allocation of a year’s 's items). If the Deconsolidation Distribution Date is not an Accounting Cutoff Date, the provisions of Treasury Regulation 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 Deconsolidation Distribution Date.
Appears in 4 contracts
Samples: Tax Sharing Agreement (Tenneco Inc /De), Tax Sharing Agreement (Newport News Shipbuilding Inc), Tax Sharing Agreement (Newport News Shipbuilding Inc)
General Method of Proration. 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 Regulation Section 1.1502-76(b) as reasonably interpreted and applied by the Companies. No election shall be made under Treasury Regulation Section 1.1502-76(b)(2)(ii) (relating to ratable allocation of a year’s 's items). If the Deconsolidation Date is not an Accounting Cutoff Date, the provisions of Treasury Regulation 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 Deconsolidation Date.
Appears in 3 contracts
Samples: Tax Matters Agreement (CST Brands, Inc.), Tax Matters Agreement (Corner Store Holdings, Inc.), Tax Sharing Agreement (Propel Inc)
General Method of Proration. In the case of any Straddle Period, Tax --------------------------- Items shall be apportioned between Pre-Deconsolidation Distribution Periods and Post-Deconsolidation Post- Distribution Periods in accordance with the principles of Treasury Regulation Section 1.1502-76(b) as reasonably interpreted and applied by the Companies. No election shall be made under Treasury Regulation Section 1.1502-76(b)(2)(ii) (relating to ratable allocation of a year’s 's items). If the Deconsolidation Distribution Date is not an Accounting Cutoff Date, the provisions of Treasury Regulation 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 Deconsolidation Distribution Date.
Appears in 2 contracts
Samples: Tax Sharing Agreement (Varian Inc), Tax Sharing Agreement (Varian Associates Inc /De/)
