Maintaining Status of Active Business. Ameriprise agrees that, from the date hereof until the first day after the second anniversary of the Distribution Date, it shall maintain the status of the Fund Management Business as an active trade or business as defined in Section 355(b)(2) of the Code and the Treasury Regulations promulgated thereunder, that is part of, or treated as part of, the Ameriprise legal entity for U.S. federal income Tax purposes.
Appears in 4 contracts
Samples: Tax Allocation Agreement, Tax Allocation Agreement (Ameriprise Financial Inc), Tax Allocation Agreement (Ameriprise Financial Inc)