Separate Return Years. To the extent any portion of a Tax Asset of the affiliated group is carried back to a pre-consolidation separate return year of the Subsidiary (whether by operation of law or at the discretion of ILIAC) the Subsidiary shall not be entitled to payment from ILIAC with respect thereto. This shall be the case whether or not that Subsidiary actually receives payment for the benefit of such Tax Asset from the Internal Revenue Service ("IRS") or from the parent of a former affiliated group.
Appears in 5 contracts
Samples: Tax Sharing Agreement (Ing Insurance Co of America), Tax Sharing Agreement (Ing Life Insurance & Annuity Co), Tax Sharing Agreement (Ing Life Insurance & Annuity Co)
Separate Return Years. To the extent any portion of a Tax Asset of the affiliated group is carried back to a pre-consolidation separate return year of the a Subsidiary (whether by operation of law or at the discretion of ILIACING U.S.) the Subsidiary shall not be entitled to payment from ILIAC with respect thereto. This shall be the case whether or not that Subsidiary actually receives payment for the benefit of such Tax Asset from the Internal Revenue Service ("IRS") or from the parent of a former affiliated group.
Appears in 2 contracts
Samples: Federal Income Tax Sharing Agreement (Ing Life Insurance & Annuity Co), Federal Income Tax Sharing Agreement (Ing Usa Annuity & Life Insurance Co)
Separate Return Years. To the extent any portion of a Tax Asset of the affiliated group is carried back to a pre-consolidation separate return year of the a Subsidiary (whether by operation of law or at the discretion of ILIACING) the Subsidiary shall not be entitled to payment from ILIAC ING with respect thereto. This shall be the case whether or not that Subsidiary actually receives payment for the benefit of such Tax Asset from the Internal Revenue Service ("IRS") or from the parent of a former affiliated group.
Appears in 2 contracts
Samples: Tax Sharing Agreement (Ing Life Insurance & Annuity Co), Tax Sharing Agreement (Ing Usa Annuity & Life Insurance Co)
Separate Return Years. To the extent any portion of a Tax Asset of the affiliated group is carried back to a pre-consolidation separate return year of the Subsidiary (whether by operation of law or at the discretion of ILIACING AIH) the Subsidiary shall not be entitled to payment from ILIAC ING AIH with respect thereto. This shall be the case whether or not that the Subsidiary actually receives payment for the benefit of such Tax Asset from the Internal Revenue Service ("IRS") or from the parent of a former affiliated group.
Appears in 1 contract
Samples: Tax Sharing Agreement (Reliastar Life Insurance Co of New York)
Separate Return Years. To the extent any portion of a Tax Asset of the affiliated group is carried back to a pre-consolidation separate return year of the a Subsidiary (whether by operation of law or at the discretion of ILIACING U.S.) the Subsidiary shall not be entitled to payment from ILIAC with respect thereto. This shall be the case whether or not that Subsidiary actually receives payment for the benefit of such Tax Asset from the Internal Revenue Service ("βIRS"β) or from the parent of a former affiliated group.
Appears in 1 contract
Samples: Federal Income Tax Sharing Agreement (ING U.S., Inc.)
Separate Return Years. To the extent any portion of a Tax Asset of the affiliated group is carried back to a pre-consolidation separate return year of the Subsidiary (whether by operation of law or at the discretion of ILIACEQUITABLE) the Subsidiary shall not be entitled to payment from ILIAC EQUITABLE with respect thereto. This shall be the case whether or not that the Subsidiary actually receives payment for the benefit of such Tax Asset from the Internal Revenue Service ("IRS") or from the parent of a former affiliated group.
Appears in 1 contract
Samples: Tax Sharing Agreement (Golden American Life Insurance Co /Ny/)
