NOL Benefit Schedule. Within ninety calendar days after the filing of the U.S. Federal income Corporation Return for the Taxable Year that includes the date of the IPO, the Corporation will provide to WTM a schedule (the “NOL Benefit Schedule”) showing, in reasonable detail, the calculation of the amount of Pre-IPO NOLs available to the Corporation after the IPO (taking into account any taxable income of GHI prior to the IPO) and any limitations on the ability of the Corporation to use the Pre-IPO NOLs after the IPO (including under Section 382 of the Code and any successor provision). Concurrently the Corporation will also provide to WTM all supporting information (including work papers and valuation reports) in its possession reasonably necessary to support the calculation of the Pre-IPO NOLs. The NOL Benefit Schedule will become final as provided in Section 2.08(a) and may be amended as provided in Section 2.08(b) (subject to the procedures set forth in Section 2.08(a)).
NOL Benefit Schedule. Within ninety calendar days after the later of (1) the date of the Initial Hybrid Exchange and (2) the receipt by the Corporation of (A) all Mercury US Returns required to be filed by Mercury US for the taxable period that immediately precedes the taxable period that includes the date of the Initial Hybrid Exchange and (B) any other information reasonably requested by the Corporation with respect to the Mercury NOLs, the Corporation will provide to Mercury Norway a schedule (the “NOL Benefit Schedule”) showing, in reasonable detail, the calculation of the amount of Mercury NOLs and any limitations on the ability of the Corporation or Mercury US, as applicable, to use the Mercury NOLs after the Initial Hybrid Exchange (including under Section 382 of the Code and any successor provision and any other applicable provision of Tax Law). The NOL Benefit Schedule will become final as provided in Section 2.07(a) and may be amended as provided in Section 2.07(b) (subject to the procedures set forth in Section 2.07(a)).
