Manner of Filing Tax Returns. Except as otherwise provided in this Section 2.3 of this Agreement, the party that is required to file a return under Section 2.1 of this Agreement (the "Filing Party") shall have the exclusive right to determine (1) the manner in which such Tax Return shall be prepared and filed, including the elections, methods of accounting, positions, conventions and principles of taxation to be used and the manner in which any Tax Item shall be reported, (2) whether any extensions may be requested, (3) the elections that will be made in such Tax Return, (4) whether any amended Tax Returns shall be filed, (5) whether any claims for refund shall be made, (6) whether any refunds shall be paid by way of refund or credited against any liability for the related Tax, and (7) whether to retain outside specialists to prepare such Tax Return, whom to retain for such purpose and the scope of any such retainer. (The party who is not the Filing Party is referred to herein as the "Non-Filing Party".)
Manner of Filing Tax Returns. (a) Southern (for itself and the Southern Affiliated Companies) and Southern Energy (for itself and the Southern Energy Affiliated Companies) agree to file all Tax Returns for any Pre-Distribution Period, and to take all other actions in a manner consistent with the position that Southern Energy and the Southern Energy Affiliated Companies are part of the Southern Consolidated Group for all periods through and including the Distribution Date.
Manner of Filing Tax Returns. (1) All Tax Returns filed after the date of this Agreement by Hewlett-Packard, any Hewlett-Packard Affiliate, Agilent and/or any Agilent Affiliate shall be (1) prepared in a manner that is consistent with (A) the Ruling Documents and (B) Sections 5.6 and 5.8 of this Agreement, and (2) filed on a timely basis (including extensions) by the party responsible for such filing under Section 2.1 of this Agreement.
Manner of Filing Tax Returns. (a) REI (for itself and the REI Affiliated Companies), REGCO (for itself and REGCO Affiliated Companies) and UNREGCO (for itself and the UNREGCO Affiliated Companies) agree to file all Tax Returns for any Pre-Distribution Period and any Straddle Period, and to take all other actions in a manner consistent with the position that UNREGCO and the UNREGCO Affiliated Companies are part of the REI Consolidated Group for Federal Income Tax purposes for all Tax periods through and including the Distribution Date.
Manner of Filing Tax Returns. (a) PRE-DECONSOLIDATION. UtiliCorp (for itself and the UtiliCorp Group) and Aquila (for itself and the Aquila Group) agree to file all Tax Returns for any Pre-Deconsolidation Period, and to take all other actions relating to Taxes, in a manner consistent with the position that Aquila and the Aquila Affiliated Group are part of the UtiliCorp Consolidated Group for all periods through and including the date upon which the Deconsolidation Event is effective.
Manner of Filing Tax Returns. (a) Unless otherwise required by a Taxing Authority, the parties hereby agree to prepare and file all Tax Returns, and to take all other actions, in a manner consistent with (1) this Agreement, (2) any Ruling Documents, and (3) any Supplemental Ruling Documents. All Tax Returns shall be filed on a timely basis (taking into account applicable extensions) by the party responsible for filing such returns under this Agreement. TRW shall prepare the Consolidated Return for the taxable year that includes the Distribution Date and shall be entitled to amend any Consolidated Return for any prior taxable year in each case as deemed necessary in its sole and absolute discretion in order for TRW to realize the Tax Benefits resulting from the Transactions in accordance with the Overriding Principle.
Manner of Filing Tax Returns. (a) All Tax Returns filed after the date of this Agreement by Centex, any Centex Affiliate, or Cavco shall be
Manner of Filing Tax Returns. 15 ---------------------------- 2.4 Review of Tax Returns.................................... 16 --------------------- 2.5 Agent.................................................... 17 -----
Manner of Filing Tax Returns. 7 2.4 Agent...............................................................8 SECTION 3.
Manner of Filing Tax Returns. (a) All Tax Returns filed after the date of this Agreement by Ford, any Ford Affiliate, Associates or any Associates Affiliate shall be (1) prepared in a manner that is consistent with (I) the Ruling Documents and (ii) Sections 5.3 and 5.6 of this Agreement, and (2) filed on a timely basis (including extensions) by the party responsible for such filing under Section 2.1 of this Agreement. (b) Ford and Associates, for itself and the Associates Affiliates, agree to file all Tax Returns for any Pre-Spinoff Period, and to take all other actions in a manner consistent with the position that Associates and the Associates Affiliates are part of any Consolidated Group and any Combined Group for all days through and including the Spinoff Date. Except as otherwise provided in this Section 2.2, Ford shall have the exclusive right, in its sole discretion, with respect to any Tax Return described in Section 2.1(a) of this Agreement to determine (1) the manner in which such Tax Return shall be prepared and filed, including the elections, methods of accounting, positions, conventions and principles of taxation to be used and the manner in which any Tax Item shall be reported, (2) whether any extensions may be requested, (3) the elections that will be made by Ford, any Ford Affiliate, Associates, and Associates Affiliate in such Tax Return, (4) whether any amended Tax Returns shall be filed, (5) whether any claims for refund shall be made, (6) whether any refunds shall be paid by way of refund or credited against any liability for the related Tax, and (7) whether to retain outside specialists to prepare such Tax Return, whom to retain for such purpose and the scope of any such retainer. Nothing in this Section 2.2 shall limit the rights of Associates under Section 7.6 of this Agreement. (d) In the event that a Tax Item is includable in a Tax Return described in Section 2.1(a) of this Agreement and also in a Tax Return described in Section 2.1(b) of this Agreement that is filed after the date of this Agreement, Associates or the Associates Affiliate preparing, or causing the preparation of, such Tax Return under Section 2.1(b) of this Agreement shall conform the treatment of such Tax Item in such Tax Return described in Section 2.1(b) of this Agreement to the treatment of such Tax Item in the applicable Tax Return described in Section 2.1(a) of this Agreement. (e) Any Tax Return described in (1) Section 2.1(a) of this Agreement (but only with respect to Tax Items of Associ...
