Payments to Loss Members a. In addition to the allocations set forth above with respect to the Group Tax Return for each Tax Period, each Profit Member for such Tax Period shall also be allocated an amount equal to the difference between (i) the federal income tax liability that would have been due on the Profit Member's separate taxable income under Section 4(a) or 5(a), as the case may be, if such party had filed a separate tax return for such Tax Period and (ii) the tax amount allocated to it under Section 4(c) or 5(c), as the case may be, (the "Additional Allocation").
Payments to Loss Members. It is expressly provided herein that REC and the Subgroups shall each be compensated by other Members or Subgroups for utilization of federal tax losses or tax credits generated by either the Parent or the Subgroups. The term "tax loss" shall include a "capital loss." There will be no payment for credits or net operating losses when used by the party which generated the losses or credits. Payment will occur between Subgroups of the REC Group when these losses or credits are utilized by parties that did not generate the losses or credits, if the total losses of loss Subgroups are not fully utilized in any one year, such utilization of federal tax losses shall be determined on a prorate basis amongst the loss Subgroups.
Payments to Loss Members a. In addition to the allocations set forth above with respect to the Group Tax Return for each Tax Period, each Profit Member for such Tax Period shall also be allocated an amount equal to the difference between (i) the federal income tax liability that would have been due on the Profit Member's separate taxable income under Section 4(a) if such party had filed a separate tax return for such Tax Period and (ii) the tax amount allocated to it under Section 4(d) (the "Additional Allocation").
Payments to Loss Members. Each Profit Member shall pay Parent such Member’s additional allocated tax liability determined under Section 4(c) or 5(c) of this Agreement. The Parent shall then pay to each Loss Member its allocable share of the total of the additional amounts due from the Profit Members. Payments for these allocable shares are to be made no later than 60 days after the date of filing of the consolidated Federal income tax return for such Tax Period.
