Common use of Limitations on Tax Attributes Clause in Contracts

Limitations on Tax Attributes. Items of income, deductions, credits and other similar items that may be limited or recharacterized on a consolidated basis (e.g., foreign tax credits, charitable contributions, section 1231 gains, etc.) shall be included in the determination of each Subsidiary's tax liability as so limited or recharacterized. For purposes of this determination, any item that is limited on a consolidated basis shall be allocated to each Subsidiary according to the ratio of (i) the amount of such item generated by a Subsidiary to (ii) the total amount of such items generated by the Group. Such items will be available for future utilization by the Group.

Limitations on Tax Attributes. Items of income, deductions, credits and other similar items that may be limited or recharacterized on a consolidated basis (e.g., foreign tax credits, charitable contributions, section 1231 gains, etc.) shall be included in the determination of each Subsidiary's ’s tax liability as so limited or recharacterized. For purposes of this determination, any item that is limited on a consolidated basis shall be allocated to each Subsidiary according to the ratio of (i) the amount of such item generated by a Subsidiary to (ii) the total amount of such items generated by the Group. Such items will be available for future utilization by the Group.