Reattribution Clause Samples
Reattribution. Continental may, at its option, elect to reattribute to itself certain Tax Items of the Holdings Group pursuant to Section 1.1502-20(g) of the Treasury Regulations. If Continental makes such election, Holdings shall comply with the requirements of Section 1.1502-20(g)(4) of the Treasury Regulations.
Reattribution. In the event of a Deconsolidation, FMC may, at its option, elect to reattribute to itself certain Tax Items of the Subsidiary Group pursuant to Section 1.1502-20(g) of the Treasury Regulations. If FMC makes such election, Subsidiary shall comply with the requirements of Section 1.1502-20(g)(5) of the Treasury Regulations.
Reattribution. In the event of a Deconsolidation, DuPont may, at its option, elect to reattribute to itself certain Tax Items of the Conoco Group pursuant to Section 1.1502-20(g) of the Treasury Regulations. If DuPont makes such election, Conoco shall comply with the requirements of Section 1.1502-20(g)(5) of the Treasury Regulations.
Reattribution. In the event of a Deconsolidation, OYO may, at its option, elect to reattribute to itself certain Tax Items of True Time pursuant to Section 1.1502-20(g) of the Treasury Regulations. If OYO makes such election, True Time shall comply with the requirements of Section1.1502-20(g)(5) of the Treasury Regulations.
Reattribution. Sellers may, at their option, elect to reattribute to themselves certain Tax Assets of the Companies and the Subsidiaries, pursuant to Treasury Regulations Section 1.1502-20(g). If Sellers make such election, Buyer shall, and shall cause the Companies and the Subsidiaries to, comply with the requirements of Treasury Regulations Section 1.1502-20(g)(5).
Reattribution. In the event of a Deconsolidation, Eaton may, at its option, elect to reattribute to itself certain Tax Items of the Axcelis Technologies Group pursuant to Section 1.1502-20(g) of the Treasury Regulations. If Eaton makes such election, Axcelis Technologies shall comply with the requirements of Section 1.1502-20(g)(5) of the Treasury Regulations.
Reattribution. In the event of a Deconsolidation, MAG may, at its option, elect to reattribute to itself certain Tax Items of the MercFuel Group pursuant to Section 1.1502-20(g) of the Treasury Regulations. If MAG makes such election, MercFuel shall comply with the requirements of Section 1.1502-20(g)(5) of the Treasury Regulations.
Reattribution. Continental may, at its option, elect to reattribute to itself certain Tax Items of the Holdings Group pursuant to Section 1.1502-20(g) of the Treasury Regulations. If Continental makes such election, Holdings shall comply with the requirements of Section 1.1502-20(g)(4) of the Treasury Regulations. Allocation of Tax Attributes. To the extent permitted by applicable law, the relevant Tax Attributes with respect to the Consolidated Group or Combined Group, as the case may be, shall be allocated (except as otherwise provided under section 5.1(b)) to the corporation or entity that created or generated such Tax Attributes. Earnings and Profits. The Federal Income Tax liability of the Consolidated Group shall, for purposes of determining the earnings and profits of each member, be allocated in accordance with the methods prescribed in Treasury Regulation section 1.1552-1(a)(2) and Treasury Regulation section 1.1502-33(d)(2)(ii) (using 100% as the fixed percentage). Additional Rights and Obligations
Reattribution. In the event of a Deconsolidation, MRV may, at its option, elect to reattribute to itself certain Tax Items of the Luminent Group pursuant to Section 1.1502-20(g) of the Treasury Regulations. If MRV makes such election, Luminent shall comply with the requirements of Section 1.1502-20(g)(5) of the Treasury Regulations.