Protective Section 336(e) Election. (a) HII will make a Protective Section 336(e) Election with respect to the Distribution. Accordingly, the Parties agree that this Agreement constitutes a written, binding agreement to make a Protective Section 336(e) Election as contemplated by Section 1.336-2(h)(1)(i) of the Regulations. SpinCo will cooperate with HII to facilitate the making of such election.
Appears in 7 contracts
Samples: Tax Matters Agreement (Resideo Technologies, Inc.), Tax Matters Agreement (Resideo Technologies, Inc.), Tax Matters Agreement (Garrett Motion Inc.)
Protective Section 336(e) Election. (a) HII DTE will make a Protective Section 336(e) Election with respect to each of the DistributionDistributions. Accordingly, the Parties agree that this Agreement constitutes a written, binding agreement to make a Protective Section 336(e) Election with respect to each of the Distributions as contemplated by Section 1.336-2(h)(1)(i) of the Regulations. SpinCo Spinco will cooperate with HII DTE to facilitate the making of such election.
Appears in 3 contracts
Samples: Tax Matters Agreement (Dte Energy Co), Tax Matters Agreement (DT Midstream, Inc.), Tax Matters Agreement (DT Midstream, Inc.)
Protective Section 336(e) Election. (a) HII will make a Protective Section 336(e) Election with respect to the Distribution. Accordingly, the Parties agree that this Agreement constitutes a written, binding agreement to make a Protective Section 336(e) Election as contemplated by Section 1.336-2(h)(1)(i) of the Regulations. SpinCo AdvanSix will cooperate with HII to facilitate the making of such election.
Appears in 3 contracts
Samples: Tax Matters Agreement (AdvanSix Inc.), Tax Matters Agreement (AdvanSix Inc.), Tax Matters Agreement (AdvanSix Inc.)
Protective Section 336(e) Election. (a) HII Vista will make a Protective Section 336(e) Election with respect to the Distribution. stock of the entities listed on Appendix C. Accordingly, the Parties agree that this Agreement constitutes a written, binding agreement to make a Protective Section 336(e) Election with respect to each such entity as contemplated by Section 1.336-2(h)(1)(i) of the Regulations. SpinCo Spinco will cooperate with HII Vista to facilitate the making of any such election.
Appears in 1 contract
Samples: Tax Matters Agreement (Outdoor Products Spinco Inc.)