Common use of Reporting of Transaction Tax Items Clause in Contracts

Reporting of Transaction Tax Items. The Tax treatment reported on any Tax Return of the Transactions shall be consistent with the treatment thereof in the Ruling Requests and the Tax Opinions/Rulings (and any Tax Return filed by MINC or any member of the MINC Group or caused to be filed by MINC, in each case with respect to periods prior to the Distribution Date or with respect to Straddle Periods), unless there is no reasonable basis for such Tax treatment. To the extent there is a Tax treatment relating to the Transactions which is not covered by the Ruling Requests or Tax Opinions/Rulings, the Companies shall agree on the Tax treatment to be reported on any Tax Return. For this purpose, the Tax treatment shall be determined by the Responsible Company with respect to such Tax Return and shall be agreed to by the other Company unless either (i) there is no reasonable basis for such Tax treatment, or (ii) such Tax treatment is inconsistent with the Tax treatment contemplated in the Ruling Requests and/or the Tax Opinions/Rulings. Such Tax Return shall be submitted for review pursuant to Section 4.06(a), and any dispute regarding such proper Tax treatment shall be referred for resolution pursuant to Section 14, sufficiently in advance of the filing date of such Tax Return (including extensions) to permit timely filing of the Tax Return.

Reporting of Transaction Tax Items. The Tax treatment reported on any Tax Return of Tax Items relating to the Transactions shall be consistent with the treatment thereof of such items in the Ruling Requests and the Tax Opinions/Rulings (and any Tax Return filed by MINC or any member of unless such treatment is not permissible under the MINC Group or caused to be filed by MINC, in each case with respect to periods prior to the Distribution Date or with respect to Straddle PeriodsCode), unless there is no reasonable basis for such Tax treatment. To the extent there is a Tax treatment Item relating to the Transactions which is not covered by the Ruling Requests or and/or the Tax Opinions/Rulings, the Companies shall agree on the Tax treatment to be of any such Tax Item reported on any Tax Return. For this purpose, the Tax treatment of such Tax Items on a Tax Return shall be determined by the Responsible Company with respect to such Tax Return and shall be agreed to by the other Company unless either (i) there is no reasonable basis for such Tax treatment, or (ii) such Tax treatment is inconsistent with the Tax treatment contemplated in the Ruling Requests Request and/or the Tax Opinions/Rulings. Such Tax Return shall be submitted for review pursuant to Section 4.06(a), and any dispute regarding such proper Tax treatment shall be referred for resolution pursuant to Section 14, sufficiently in advance of the filing date of such Tax Return (including extensions) to permit timely filing of the Tax Return.