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.
Appears in 4 contracts
Samples: Tax Allocation Agreement (Ralcorp Holdings Inc /Mo), Tax Allocation Agreement (Cable Holdco, Inc.), Tax Allocation Agreement (Ralcorp Holdings Inc /Mo)