SpinCo Group Attributes Sample Clauses
The 'SpinCo Group Attributes' clause defines the specific tax attributes, such as net operating losses, credits, or other carryforwards, that are allocated to the SpinCo entity following a corporate spin-off or separation. In practice, this clause outlines which tax benefits or obligations are transferred to SpinCo, often referencing applicable tax laws or agreements between the parent company and SpinCo. Its core function is to ensure clarity and prevent disputes by explicitly stating how valuable tax attributes are divided between the separating entities.
SpinCo Group Attributes. For the avoidance of doubt (but without prejudice to the provisos set forth in Sections 2.02(a)(i) and (ii)), except as set forth in Section 6.01, SpinCo shall not be entitled to receive payment from Distributing in respect of any SpinCo Group Attributes or for any reduction of any Taxes (or increase in Tax Attributes) or any Tax Benefit (whether such Tax Attributes, Tax Benefits or reduction in Taxes are reported on an original Tax Return, arise pursuant to a Final Determination or otherwise).