Interest and Penalties. a. If, after netting interest payable by the LNC Consolidated Group against interest payable by the IRS for a given Tax Year, the LNC Consolidated Group is required to pay interest to the IRS as a result of any increase in tax liability for a given Tax Year, such interest shall be divided among all of the corporations in the LNC Consolidated Group whose tax liability increased from the initial calculation at the time of the filing of the LNC consolidated tax return for that Tax Year. This allocation shall be made in proportion to the increase in tax liability of CIA as compared to the increase in tax liability of all members of the LNC Consolidated Group. b. If, after netting interest payable by the LNC Consolidated Group against interest payable by the IRS for a given Tax Year, the LNC Consolidated Group is entitled to receive interest from the IRS as a result of any decrease in tax liability for a given Tax Year, such interest shall also be divided among all of the corporations in the LNC Consolidated Group whose tax liability decreased from the initial calculation at the time of the filing of the LNC consolidated tax return for that Tax Year. This allocation shall be made in proportion to the decrease in tax liability of CIA as compared to the decrease in tax liability of all members of the LNC Consolidated Group. c. Any tax penalties imposed by a taxing authority shall be the responsibility of the corporation whose tax position or tax item caused the imposition of such penalties.
Appears in 1 contract
Samples: Tax Sharing Agreement (American States Financial Corp)
Interest and Penalties. a. If, after netting interest payable by the LNC Consolidated Group against interest payable by the IRS for a given Tax Year, the LNC Consolidated Group is required to pay interest to the IRS as a result of any increase in tax liability for a given Tax Year, such interest shall be divided among all of the corporations in the LNC Consolidated Group whose tax liability increased from the initial calculation at the time of the filing of the LNC consolidated tax return for that Tax Year. This allocation shall be made in proportion to the increase in tax liability of CIA ASIC as compared to the increase in tax liability of all members of the LNC Consolidated Group.
b. If, after netting interest payable by the LNC Consolidated Group against interest payable by the IRS for a given Tax Year, the LNC Consolidated Group is entitled to receive interest from the IRS as a result of any decrease in tax liability for a given Tax Year, such interest shall also be divided among all of the corporations in the LNC Consolidated Group whose tax liability decreased from the initial calculation at the time of the filing of the LNC consolidated tax return for that Tax Year. This allocation shall be made in proportion to the decrease in tax liability of CIA ASIC as compared to the decrease in tax liability of all members of the LNC Consolidated Group.
c. Any tax penalties imposed by a taxing authority shall be the responsibility of the corporation whose tax position or tax item caused the imposition of such penalties.
Appears in 1 contract
Samples: Tax Sharing Agreement (American States Financial Corp)
Interest and Penalties. a. If, after netting interest payable by the LNC Consolidated Group against interest payable by the IRS for a given Tax Year, the LNC Consolidated Group is required to pay interest to the IRS as a result of any increase in tax liability for a given Tax Year, such interest shall be divided among all of the corporations in the LNC Consolidated Group whose tax liability increased from the initial calculation at the time of the filing of the LNC consolidated tax return for that Tax Year. This allocation shall be made in proportion to the increase in tax liability of CIA Linsco as compared to the increase in tax liability of all members of the LNC Consolidated Group.
b. If, after netting interest payable by the LNC Consolidated Group against interest payable by the IRS for a given Tax Year, the LNC Consolidated Group is entitled to receive interest from the IRS as a result of any decrease in tax liability for a given Tax Year, such interest shall also be divided among all of the corporations in the LNC Consolidated Group whose tax liability decreased from the initial calculation at the time of the filing of the LNC consolidated tax return for that Tax Year. This allocation shall be made in proportion to the decrease in tax liability of CIA Linsco as compared to the decrease in tax liability of all members of the LNC Consolidated Group.
c. Any tax penalties imposed by a taxing authority shall be the responsibility of the corporation whose tax position or tax item caused the imposition of such penalties.
Appears in 1 contract
Samples: Tax Sharing Agreement (American States Financial Corp)
Interest and Penalties. a. If, after netting interest payable by the LNC Consolidated Group against interest payable by the IRS for a given Tax Year, the LNC Consolidated Group is required to pay interest to the IRS as a result of any increase in tax liability for a given Tax Year, such interest shall be divided among all of the corporations in the LNC Consolidated Group whose tax liability increased from the initial calculation at the time of the filing of the LNC consolidated tax return for that Tax Year. This allocation shall be made in proportion to the increase in tax liability of CIA ASLI as compared to the increase in tax liability of all members of the LNC Consolidated Group.
b. If, after netting interest payable by the LNC Consolidated Group against interest payable by the IRS for a given Tax Year, the LNC Consolidated Group is entitled to receive interest from the IRS as a result of any decrease in tax liability for a given Tax Year, such interest shall also be divided among all of the corporations in the LNC Consolidated Group whose tax liability decreased from the initial calculation at the time of the filing of the LNC consolidated tax return for that Tax Year. This allocation shall be made in proportion to the decrease in tax liability of CIA ASLI as compared to the decrease in tax liability of all members of the LNC Consolidated Group.
c. Any tax penalties imposed by a taxing authority shall be the responsibility of the corporation whose tax position or tax item caused the imposition of such penalties.
Appears in 1 contract
Samples: Tax Sharing Agreement (American States Financial Corp)
Interest and Penalties. a. If, after netting interest payable by the LNC Consolidated Group against interest payable by the IRS for a given Tax Year, the LNC Consolidated Group is required to pay interest to the IRS as a result of any increase in tax liability for a given Tax Year, such interest shall be divided among all of the corporations in the LNC Consolidated Group whose tax liability increased from the initial calculation at the time of the filing of the LNC consolidated tax return for that Tax Year. This allocation shall be made in proportion to the increase in tax liability of CIA the ASFC Group as compared to the increase in tax liability of all other members of the LNC Consolidated Group.
b. If, after netting interest payable by the LNC Consolidated Group against interest payable by the IRS for a given Tax Year, the LNC Consolidated Group is entitled to receive interest from the IRS as a result of any decrease in tax liability for a given Tax Year, such interest shall also be divided among all of the corporations in the LNC Consolidated Group whose tax liability decreased from the initial calculation at the time of the filing of the LNC consolidated tax return for that Tax Year. This allocation shall be made in proportion to the decrease in tax liability of CIA the ASFC Group as compared to the decrease in tax liability of all other members of the LNC Consolidated Group.
c. Any tax penalties imposed by a taxing authority shall be the responsibility of the corporation whose tax position or tax item caused the imposition of such penalties.
Appears in 1 contract
Samples: Tax Sharing Agreement (American States Financial Corp)
Interest and Penalties. a. If, after netting interest payable by the LNC Consolidated Group against interest payable by the IRS for a given Tax Year, the LNC Consolidated Group is required to pay interest to the IRS as a result of any increase in tax liability for a given Tax Year, such interest shall be divided among all of the corporations in the LNC Consolidated Group whose tax liability increased from the initial calculation at the time of the filing of the LNC consolidated tax return for that Tax Year. This allocation shall be made in proportion to the increase in tax liability of CIA AST as compared to the increase in tax liability of all members of the LNC Consolidated Group.
b. If, after netting interest payable by the LNC Consolidated Group against interest payable by the IRS for a given Tax Year, the LNC Consolidated Group is entitled to receive interest from the IRS as a result of any decrease in tax liability for a given Tax Year, such interest shall also be divided among all of the corporations in the LNC Consolidated Group whose tax liability decreased from the initial calculation at the time of the filing of the LNC consolidated tax return for that Tax Year. This allocation shall be made in proportion to the decrease in tax liability of CIA AST as compared to the decrease in tax liability of all members of the LNC Consolidated Group.
c. Any tax penalties imposed by a taxing authority shall be the responsibility of the corporation whose tax position or tax item caused the imposition of such penalties.
Appears in 1 contract
Samples: Tax Sharing Agreement (American States Financial Corp)
Interest and Penalties. a. If, after netting interest payable by the LNC Consolidated Group against interest payable by the IRS for a given Tax Year, the LNC Consolidated Group is required to pay interest to the IRS as a result of any increase in tax liability for a given Tax Year, such interest shall be divided among all of the corporations in the LNC Consolidated Group whose tax liability increased from the initial calculation at the time of the filing of the LNC consolidated tax return for that Tax Year. This allocation shall be made in proportion to the increase in tax liability of CIA ICI as compared to the increase in tax liability of all members of the LNC Consolidated Group.
b. If, after netting interest payable by the LNC Consolidated Group against interest payable by the IRS for a given Tax Year, the LNC Consolidated Group is entitled to receive interest from the IRS as a result of any decrease in tax liability for a given Tax Year, such interest shall also be divided among all of the corporations in the LNC Consolidated Group whose tax liability decreased from the initial calculation at the time of the filing of the LNC consolidated tax return for that Tax Year. This allocation shall be made in proportion to the decrease in tax liability of CIA ICI as compared to the decrease in tax liability of all members of the LNC Consolidated Group.
c. Any tax penalties imposed by a taxing authority shall be the responsibility of the corporation whose tax position or tax item caused the imposition of such penalties.
Appears in 1 contract
Samples: Tax Sharing Agreement (American States Financial Corp)
Interest and Penalties. a. If, after netting interest payable by the LNC Consolidated Group against interest payable by the IRS for a given Tax Year, the LNC Consolidated Group is required to pay interest to the IRS as a result of any increase in tax liability for a given Tax Year, such interest shall be divided among all of the corporations in the LNC Consolidated Group whose tax liability increased from the initial calculation at the time of the filing of the LNC consolidated tax return for that Tax Year. This allocation shall be made in proportion to the increase in tax liability of CIA AEIC as compared to the increase in tax liability of all members of the LNC Consolidated Group.
b. If, after netting interest payable by the LNC Consolidated Group against interest payable by the IRS for a given Tax Year, the LNC Consolidated Group is entitled to receive interest from the IRS as a result of any decrease in tax liability for a given Tax Year, such interest shall also be divided among all of the corporations in the LNC Consolidated Group whose tax liability decreased from the initial calculation at the time of the filing of the LNC consolidated tax return for that Tax Year. This allocation shall be made in proportion to the decrease in tax liability of CIA AEIC as compared to the decrease in tax liability of all members of the LNC Consolidated Group.
c. Any tax penalties imposed by a taxing authority shall be the responsibility of the corporation whose tax position or tax item caused the imposition of such penalties.
Appears in 1 contract
Samples: Tax Sharing Agreement (American States Financial Corp)
Interest and Penalties. a. If, after netting interest payable by the LNC Consolidated Group against interest payable by the IRS for a given Tax Year, the LNC Consolidated Group is required to pay interest to the IRS as a result of any increase in tax liability for a given Tax Year, such interest shall be divided among all of the corporations in the LNC Consolidated Group whose tax liability increased from the initial calculation at the time of the filing of the LNC consolidated tax return for that Tax Year. This allocation shall be made in proportion to the increase in tax liability of CIA ASL as compared to the increase in tax liability of all members of the LNC Consolidated Group.
b. If, after netting interest payable by the LNC Consolidated Group against interest payable by the IRS for a given Tax Year, the LNC Consolidated Group is entitled to receive interest from the IRS as a result of any decrease in tax liability for a given Tax Year, such interest shall also be divided among all of the corporations in the LNC Consolidated Group whose tax liability decreased from the initial calculation at the time of the filing of the LNC consolidated tax return for that Tax Year. This allocation shall be made in proportion to the decrease in tax liability of CIA ASL as compared to the decrease in tax liability of all members of the LNC Consolidated Group.
c. Any tax penalties imposed by a taxing authority shall be the responsibility of the corporation whose tax position or tax item caused the imposition of such penalties.
Appears in 1 contract
Samples: Tax Sharing Agreement (American States Financial Corp)
Interest and Penalties. a. If, after netting interest payable by the LNC Consolidated Group against interest payable by the IRS for a given Tax Year, the LNC Consolidated Group is required to pay interest to the IRS as a result of any increase in tax liability for a given Tax Year, such interest shall be divided among all of the corporations in the LNC Consolidated Group whose tax liability increased from the initial calculation at the time of the filing of the LNC consolidated tax return for that Tax Year. This allocation shall be made in proportion to the increase in tax liability of CIA ASP as compared to the increase in tax liability of all members of the LNC Consolidated Group.
b. If, after netting interest payable by the LNC Consolidated Group against interest payable by the IRS for a given Tax Year, the LNC Consolidated Group is entitled to receive interest from the IRS as a result of any decrease in tax liability for a given Tax Year, such interest shall also be divided among all of the corporations in the LNC Consolidated Group whose tax liability decreased from the initial calculation at the time of the filing of the LNC consolidated tax return for that Tax Year. This allocation shall be made in proportion to the decrease in tax liability of CIA ASP as compared to the decrease in tax liability of all members of the LNC Consolidated Group.
c. Any tax penalties imposed by a taxing authority shall be the responsibility of the corporation whose tax position or tax item caused the imposition of such penalties.
Appears in 1 contract
Samples: Tax Sharing Agreement (American States Financial Corp)