Other Income Taxes. Without regard to anything to the contrary in this Article II, ADP shall be liable, and shall indemnify the Dealer Group, for all Taxes arising as a result of the Transactions from (i) excess loss accounts taken into account under Code Section 1502, (ii) Code Section 357(c) or (iii) Code Section 361(b), in each case, including under similar state and local law provisions. Any Taxes attributable to deferred intercompany gains that are triggered as a result of the Transactions shall be the responsibility of ADP and shall not be included in determining the Dealer Group’s Income Tax liability. To the extent there are adjustments to the amount of any deferred intercompany gain triggered as a result of the Distribution, ADP shall be responsible for paying the additional Tax associated with any increase in the amount of gain and shall also be entitled to a Refund attributable to any reduction of gain.
Other Income Taxes. For the avoidance of doubt, any Tax Item resulting from Splitco ceasing to be a member of the Parent Group (including any Tax Items required to be taken into account by the Parent Group under Treas. Reg. §§ 1.1502-13 and 1.1502-19) shall be treated as arising in the Pre-Distribution Period.
Other Income Taxes. Except to the extent required by law, for the avoidance of doubt, any Tax Item resulting from Post and/or its subsidiaries ceasing to be members of the Ralcorp Group (including any Tax Items required to be taken into account by the Ralcorp Group under Treas. Reg. Sections 1.1502-13 and 1.1502-19) shall be treated as arising in the Pre-Distribution Period.
Other Income Taxes. In the event there shall be imposed on the Subsidiary any state or local tax based on net income to which the same or similar principles of consolidated income taxation such as those presently in effect under Federal income tax rules may be applied and practical, the Subsidiary and the Company agree that the above agreements shall also be applicable with respect to such state or local income taxes.
Other Income Taxes. The Weyerhaeuser Group shall be responsible for, and shall indemnify and hold harmless the Spinco Group from and against, Taxes arising as a result of the Transactions (i) from excess loss accounts or deferred intercompany transactions taken into account under Code Section 1502 or Treasury Regulation issued thereunder or (ii) under Code Section 361(b). Notwithstanding the foregoing, the Spinco Group shall be liable, and shall indemnify the Weyerhaeuser Group, for Transaction Taxes to the extent provided in Section 2.02(a).
Other Income Taxes. Without regard to anything to the contrary in Exhibit A, Sprint Nextel shall be liable, and shall indemnify the Embarq Group, for all Taxes arising as a result of the Transactions from (i) excess loss accounts taken into account under Code Section 1502, (ii) Code Section 357(c) or (iii) Code Section 361(b), in each case, including under similar state law provisions. Deferred intercompany gains will be governed solely by Exhibit A. Notwithstanding the foregoing, Embarq shall be liable, and shall indemnify Sprint Nextel, for Transaction Taxes arising on the issuance of Embarq securities to Sprint Nextel as a result of Embarq’s actions or failure to take actions following the Distribution with respect to such securities.
Other Income Taxes. Except as otherwise provided in this Agreement, the liability for any Other Income Tax shall be allocated as follows:
Other Income Taxes. In the event there shall be imposed on CMS any state or local tax based on net income to which the principles of consolidated income taxation such as those presently in effect under Federal income tax rules may be applied and practical, CMS and the Holding Company agree that the above agreements shall also be applicable with respect to such state or local income taxes.
Other Income Taxes. The principles and procedures (including the indemnity in paragraph 5) stated in this Agreement shall apply for purposes of allocating any tax liability for any Combined Return for any taxable year or period after 2000 Taxable Year. For instance, if Parent files a Combined Return, AHI shall reimburse Parent for the amount of any tax liability to the extent the tax liability is paid by the Parent and is attributable to the operations of AHI or to any AHI Group Member. For the avoidance of doubt, each member of the AHI Group shall otherwise be responsible for its own Other Income Taxes, and all other taxes.
Other Income Taxes. Subsidiary and Hollywood shall cooperate in making similar determination of the Hollywood Group's income tax liabilities to other taxing jurisdictions on or before the dates on which payments are required to be made to such jurisdictions. Subsidiary shall also make periodic tax payments to Hollywood, in an amount equal to (i) Hollywood's required payment multiplied by (ii) the estimated Subsidiary Group Percentage, to allow Hollywood to satisfy those liabilities in a timely manner. 5.
