Common use of Reporting of Transactions in a Manner Consistent with Intended Tax Treatment Clause in Contracts

Reporting of Transactions in a Manner Consistent with Intended Tax Treatment. (a) The Parties agree to treat the Separation Transactions in a manner consistent with the intended tax treatment of the Separation Transactions set forth in Section 2.01. Without limiting the foregoing, all Tax Returns prepared by or on behalf of any Party shall be prepared in a manner consistent with the intended tax treatment of the Separation Transactions set forth in Section 2.01, and no Party shall take any contrary or inconsistent position, whether in a Tax Return or otherwise, including any dealings involving the Internal Revenue Service (including, without limitation, any audit, administrative appeal or any judicial proceeding involving the Tax Returns of the Party or the tax treatment of any Party).