Spinco Group. For purposes of this Agreement, the "Spinco Group" shall mean (i) Spinco, (ii) Spinco's subsidiaries, and (iii) those corporations and other entities whose stock or ownership interests will be contributed to Spinco prior to the Spin-Off Date, all of such subsidiaries of Spinco and such corporations and other entities being listed on Exhibit A attached hereto. Unless otherwise specified, whenever Items of Loss or Tax Benefit (as defined below) of Spinco are referred to in this Agreement the reference shall be to the collective amounts of such items for the Spinco Group. For purposes of this Agreement, items of income, gain, loss, deduction, credit, or other Tax attributes are referred to as "Items of Loss or Tax Benefit".
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Samples: Tax Allocation Agreement (Plains Resources Inc), Tax Allocation Agreement (Plains Exploration & Production Co L P)
Spinco Group. For purposes of this Agreement, the "Spinco Group" shall mean (i) Spinco, (ii) Spinco's subsidiaries, and (iii) those corporations and other entities whose stock or ownership interests will be contributed to Spinco prior to the Spin-Off Date, all of such subsidiaries of Spinco and such corporations and other entities being listed on Exhibit A attached hereto. Unless otherwise specified, whenever Items of Loss or Tax Benefit (as defined below) of Spinco are referred to in this Agreement the reference shall be to the collective amounts of such items for the Spinco Group. For purposes of this Agreement, items of income, gain, loss, deduction, credit, or other Tax attributes on or prior to the Spin-Off Date are referred to as "Items of Loss or Tax Benefit".
Appears in 1 contract
Samples: Tax Allocation Agreement (Plains Exploration & Production Co)
Spinco Group. For purposes of this Agreement, the "Spinco Group" shall mean (i) Spinco, (ii) Spinco's subsidiaries, and (iii) those corporations and other entities whose stock or ownership interests will be contributed to Spinco prior to the Spin-Off Date, all of such subsidiaries of Spinco and such corporations and other entities being listed on Exhibit A attached hereto. Unless otherwise specified, whenever Items of Loss or Tax Benefit (as defined below) of Spinco are referred to in this Agreement the reference shall be to the collective amounts of such items for the Spinco Group. For purposes of this Agreement, items of income, gain, loss, deduction, credit, or other Tax attributes of Spinco are referred to as in this Agreement (hereinafter "Items of Loss or Tax Benefit"), the reference shall be to the collective amounts of such items for the Spinco Group.
Appears in 1 contract
Samples: Tax Allocation Agreement (Plains Exploration & Production Co L P)