General Method of Proration. 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 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 Tax Items). If the 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 Tax Items (other than extraordinary items) for the month which includes the Distribution Date.
Appears in 3 contracts
Samples: Tax Sharing Agreement, Tax Sharing Agreement (Phillips 66), Tax Sharing Agreement (Phillips 66)
General Method of Proration. 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 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 Tax Items's items). If the Distribution Date is not an Accounting Cutoff Date, the provisions principles of Treasury Regulation Section 1.1502-76(b)(2)(iii76 (b)(2)(iii) will be applied to ratably allocate the Tax Items items (other than extraordinary itemsitems described in Treasury Regulation Section 1.1502-76(b)(2)(ii)(C)) for the month which includes the Distribution Date.
Appears in 3 contracts
Samples: Distribution Agreement (Pactiv Corp), Tax Sharing Agreement (Tenneco Packaging Inc), Distribution Agreement (Tenneco Packaging Inc)
General Method of Proration. 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 Regulation Regulations Section 1.1502-76(b) as reasonably interpreted and applied by the Companies. No election shall be made under Treasury Regulation Regulations Section 1.1502-76(b)(2)(ii) (relating to ratable allocation of a year’s Tax Items). If the Distribution Date is not an Accounting Cutoff Date, the provisions of Treasury Regulation Regulations Section 1.1502-76(b)(2)(iii) will be applied to ratably allocate the Tax Items (other than extraordinary itemsTax Items) for the month which includes the Distribution Date.
Appears in 3 contracts
Samples: Tax Matters Agreement (Arconic Inc.), Tax Matters Agreement (Alcoa Upstream Corp), Tax Matters Agreement
General Method of Proration. 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 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 Tax Items's items). If the 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 Tax Items items (other than extraordinary items) for the month which includes the Distribution Date.
Appears in 3 contracts
Samples: Tax Sharing Agreement (Commscope Inc), Tax Sharing Agreement (General Semiconductor Inc), Tax Matters Agreement (Us Neurosurgical Inc)
General Method of Proration. 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 Regulation Regulations Section 1.1502-76(b) and any other applicable Tax Law as reasonably interpreted and applied by the CompaniesParent. No election shall be made under Treasury Regulation Regulations Section 1.1502-76(b)(2)(ii) (relating to ratable allocation of a year’s Tax Items). If the Distribution Date is not an Accounting Cutoff Date, the provisions of Treasury Regulation Regulations Section 1.1502-76(b)(2)(iii) will shall be applied to ratably allocate the Tax Items (other than extraordinary itemsTax Items) for the month which includes the Distribution Date.
Appears in 2 contracts
Samples: Tax Matters Agreement (Howmet Aerospace Inc.), Tax Matters Agreement (Arconic Rolled Products Corp)
General Method of Proration. 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 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 Tax Items's items). If the Distribution Date is not an Accounting Cutoff Date, the provisions principles of Treasury Regulation Section 1.1502-76(b)(2)(iii) will be applied to ratably allocate the Tax Items items (other than extraordinary itemsitems described in Treasury Regulation Section 1.1502-76(b)(2)(ii)(C)) for the month which includes the Distribution Date.
Appears in 2 contracts
Samples: Distribution Agreement (Tenneco Packaging Inc), Distribution Agreement (Tenneco Packaging Inc)