Common use of Separate Return Years Clause in Contracts

Separate Return Years. (i) Except as provided in Section 2.1(b)(ii), TODCO shall be liable for all Federal Income Taxes imposed on members of the TODCO Tax Group with respect to all Separate Return Years. (ii) TODCO shall not be liable for any Federal Income Taxes imposed on members of the TODCO Tax Group (x) for any Separate Return Year which ends on or before the IPO Closing Date or (y) in the case of a Separate Return Year which is a Straddle Period, for the portion thereof which ends on the IPO Closing Date. Notwithstanding the immediately preceding sentence, if any member of the TODCO Tax Group becomes a member of such Group after the IPO Closing Date (determined after the application of Section 2.5(a) of this Agreement), TODCO shall be liable for all Federal Income Taxes imposed on such member for all Separate Return Years. (iii) Holdings shall indemnify TODCO and its Subsidiaries for all Federal Income Taxes for all Tax Years which are not Consolidated Years other than amounts for which TODCO is liable pursuant to this Section 2.1(b).

Separate Return Years. (i) Except as provided in Section 2.1(b)(ii2.3(b)(ii), TODCO shall be liable for all Federal Foreign Income Taxes imposed on members of the TODCO Tax Group with respect to all Separate Return Years. (ii) TODCO shall not be liable for any Federal Foreign Income Taxes imposed on members of the TODCO Tax Group (x) for any Separate Return Year which ends on or before the IPO Closing Date or (y) in the case of a Separate Return Year which is a Straddle Period, for the portion thereof which ends on the IPO Closing Date. Notwithstanding the immediately preceding sentence, if any member of the TODCO Tax Group becomes a member of such Group after the IPO Closing Date (determined after the application of Section 2.5(a) of this Agreement), TODCO shall be liable for all Federal Foreign Income Taxes imposed on such member for all Separate Return Years. (iii) Holdings shall indemnify TODCO and its Subsidiaries for all Federal Foreign Income Taxes for all Tax Years which are not Consolidated Separate Return Years other than amounts for which TODCO is liable pursuant to this Section 2.1(b2.3(b).

Separate Return Years. (i) Except as provided in Section 2.1(b)(ii2.2(b)(ii), TODCO shall be liable for all Federal State Income Taxes imposed on members of the TODCO Tax Group with respect to all Separate Return Years. (ii) TODCO shall not be liable for any Federal State Income Taxes imposed on members of the TODCO Tax Group (x) for any Separate Return Year which ends on or before the IPO Closing Date or (y) in the case of a Separate Return Year which is a Straddle Period, for the portion thereof which ends on the IPO Closing Date. Notwithstanding the immediately preceding sentence, if any member of the TODCO Tax Group becomes a member of such Group after the IPO Closing Date (determined after the application of Section 2.5(a) of this Agreement), TODCO shall be liable for all Federal State Income Taxes imposed on such member for all Separate Return Years. (iii) Holdings shall indemnify TODCO and its Subsidiaries for all Federal State Income Taxes for all Tax Years which are not Consolidated Separate Return Years other than amounts for which TODCO is liable pursuant to this Section 2.1(b2.2(b).