PRO RATA ALLOCATION OF TAX ITEMS. The Company shall be required to allocate the tax items described in Section 1362(e)(2)(A) of the Code between the S Short Year and the C Short Year pursuant to the pro rata allocation rules set forth in Section 1362(e)(2)(B) of the Code.
Appears in 4 contracts
Samples: Corporation Distribution Agreement (Otg Software Inc), Corporation Distribution Agreement (Otg Software Inc), Corporation Distribution Agreement (MKS Instruments Inc)