Protective Section 336(e) Elections. (a) The Parties shall, at Select’s election, timely enter into a written, binding agreement (within the meaning of Section 1.336-2(h)(1)(i) of the Regulations) to make a Protective Section 336(e) Election with respect to the Distribution. Select shall timely make such Protective Section 336(e) Election and timely file such forms as may be contemplated by applicable Tax Law or administrative practice to effect such Protective Section 336(e) Election and shall have the exclusive right to prepare and file (i) the relevant purchase price allocation and any corresponding IRS Form 8883 (or any successor thereto) and (ii) any similar forms required or permitted to be filed under U.S. state or local Law in connection with such Protective Section 336(e) Election. Concentra will cooperate with Select to facilitate the making of such election.
Appears in 4 contracts
Samples: Tax Matters Agreement (Concentra Group Holdings Parent, Inc.), Tax Matters Agreement (Select Medical Holdings Corp), Tax Matters Agreement (Concentra Group Holdings Parent, Inc.)
