Remainco Consolidated Return. Remainco shall prepare and file all Remainco Consolidated Returns for a Pre-Distribution Period or a Straddle Period. Notwithstanding anything to the contrary in this Agreement, for all Tax purposes, the Parties shall report any Extraordinary Transactions that are effected by the Spinco Group on the Distribution Date after the Effective Time as occurring on the day after the Distribution Date to the extent permitted by Treasury Regulations Section 1.1502-76(b)(1)(ii)(B) or any similar or analogous provision of state, local or non-U.S. Law.
Remainco Consolidated Return. Remainco shall prepare and file all Remainco Consolidated Returns for a Pre-Distribution Period or a Straddle Period. (b) Merger Partner Consolidated Return. Merger Partner shall prepare and file all Merger Partner Consolidated Returns for a Pre-Distribution Period or a Straddle Period. (c)
Remainco Consolidated Return. Remainco shall prepare and file all Remainco Consolidated Returns for a Pre-Closing Period or a Straddle Period.