Common use of Stand Alone Method Clause in Contracts

Stand Alone Method. The following rules shall apply for purposes of computing Ribapharm's liability under the Stand Alone Method: (i) transactions during any Consolidated Period between a member of the Ribapharm Group and a member of the ICN Group that is not a member of the Ribapharm Group shall, for Federal Income Tax purposes, be accounted for pursuant to the provisions of the regulations under IRC Section 1502 that govern intercompany transactions (and to the extent appropriate for State or Foreign Income Tax purposes, similar rules shall apply in the case of transactions between such members which are included in State or Foreign Consolidated or Combined Income Tax Returns); (ii) during Consolidated Periods all computations shall be made in conformity with the positions, elections and accounting methods used by ICN in preparing the consolidated returns of the ICN Group; (iii) the highest marginal tax rate to which the Ribapharm Group could be subject under applicable Tax Law shall be deemed to be the only Tax rate to which such group is subject under such law; and (iv) subject to (i) through (iii) above, all computations and other determinations shall be made in accordance with the the laws and regulations applying to affiliated groups filing consolidated returns (including, in the case of any company that becomes or ceases to be a member of any Group, the laws and regulations applicable to a company that becomes or ceases to be a member of a such Group), as well as all other relevant federal Tax laws and regulations (and similar rules shall apply in the case of State or Foreign Taxes in respect to Consolidated or Combined Returns for such Taxes).

Appears in 2 contracts

Samples: Tax Sharing Agreement (Ribapharm Inc), Tax Sharing Agreement (Ribapharm Inc)

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Stand Alone Method. The following rules shall apply for purposes of computing RibapharmRIBAPHARM's liability under the Stand Alone Method: : (i) transactions during any Consolidated Period between a member of the Ribapharm RIBAPHARM Group and a member of the ICN Group that is not a member of the Ribapharm RIBAPHARM Group shall, for Federal Income Tax purposes, be accounted for pursuant to the provisions of the regulations under IRC Section 1502 that -11- 14 govern intercompany transactions (and to the extent appropriate for State or Foreign Income Tax purposes, similar rules shall apply in the case of transactions between such members which are included in State or Foreign Consolidated or Combined Income Tax Returns); (ii) during Consolidated Periods all computations shall be made in conformity with the positions, elections and accounting methods used by ICN in preparing the consolidated returns of the ICN Group; (iii) the highest marginal tax rate to which the Ribapharm RIBAPHARM Group could be subject under applicable Tax Law shall be deemed to be the only Tax rate to which such group is subject under such law; and (iv) subject to (i) through (iii) above, all computations and other determinations shall be made in accordance with the the laws and regulations applying to affiliated groups filing consolidated returns (including, in the case of any company that becomes or ceases to be a member of any Group, the laws and regulations applicable to a company that becomes or ceases to be a member of a such Group), as well as all other relevant federal Tax laws and regulations (and similar rules shall apply in the case of State or Foreign Taxes in respect to Consolidated or Combined Returns for such Taxes).

Appears in 1 contract

Samples: Tax Sharing Agreement (Ribapharm Inc)

Stand Alone Method. The following rules shall apply for purposes of computing RibapharmRIBAPHARM's liability under the Stand Alone Method: : (i) transactions during any Consolidated Period between a member of the Ribapharm RIBAPHARM Group and a member of the ICN Group that is not a member of the Ribapharm RIBAPHARM Group shall, for Federal Income Tax purposes, be accounted for pursuant to the provisions of the regulations under IRC Section 1502 that govern intercompany transactions (and to the extent appropriate for State or Foreign Income Tax purposes, similar rules shall apply in the case of transactions between such members which are included in State or Foreign Consolidated or Combined Income Tax Returns); (ii) during Consolidated Periods all computations shall be made in conformity with the positions, elections and accounting methods used by ICN in preparing the consolidated returns of the ICN Group; (iii) the highest marginal tax rate to which the Ribapharm RIBAPHARM Group could be subject under applicable Tax Law shall be deemed to be the only Tax rate to which such group is subject under such law; and (iv) subject to (i) through (iii) above, all computations and other determinations shall be made in accordance with the the laws and regulations applying to affiliated groups filing consolidated returns (including, in the case of any company that becomes or ceases to be a member of any Group, the laws and regulations applicable to a company that becomes or ceases to be a member of a such Group), as well as all other relevant federal Tax laws and regulations (and similar rules shall apply in the case of State or Foreign Taxes in respect to Consolidated or Combined Returns for such Taxes).. (b) The principles of Treasury Regulation Section 1.1502-76

Appears in 1 contract

Samples: Tax Sharing Agreement (Ribapharm Inc)

Stand Alone Method. The following rules shall apply for purposes of computing RibapharmRIBAPHARM's liability under the Stand Alone Method: : (i) transactions during any Consolidated Period between a member of the Ribapharm RIBAPHARM Group and a member of the ICN Group that is not a member of the Ribapharm RIBAPHARM Group shall, for Federal Income Tax purposes, be accounted for pursuant to the provisions of the regulations under IRC Section 1502 that govern intercompany transactions (and to the extent appropriate for State or Foreign Income Tax purposes, similar rules shall apply in the case of transactions between such members which are included in State or Foreign Consolidated or Combined Income Tax Returns); (ii) during Consolidated Periods all computations shall be made in conformity with the positions, elections and accounting methods used by ICN in preparing the consolidated returns of the ICN Group; (iii) the highest marginal tax rate to which the Ribapharm RIBAPHARM Group could be subject under applicable Tax Law shall be deemed to be the only Tax rate to which such group is subject under such law; and (iv) subject to (i) through (iii) above, all computations and other determinations shall be made in accordance with the the laws and regulations applying to affiliated groups filing consolidated returns (including, in the case of any company that becomes or ceases to be a member of any Group, the laws and regulations applicable to a company that becomes or ceases to be a member of a such Group), as well as all other relevant federal Tax laws and regulations (and similar rules shall apply in the case of State or Foreign Taxes in respect to Consolidated or Combined Returns for such Taxes).

Appears in 1 contract

Samples: Tax Sharing Agreement (Ribapharm Inc)

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Stand Alone Method. The following rules shall apply for purposes of computing RibapharmCMC's liability under the Stand Alone Method: Method - (i) transactions during any Consolidated Period between a member of the Ribapharm CMC Group and a member of the ICN Cabot Group that is not a member of the Ribapharm CMC Group shall, for Federal Income Tax purposes, be accounted for pursuant to the provisions of the regulations under IRC Section 1502 that govern intercompany transactions (and to the extent appropriate for State or Foreign Income Tax purposes, similar rules shall apply in the case of transactions between such members which are included in State or Foreign Combined or Consolidated or Combined Income Tax Returns), provided that the pricing of the provision of goods and services in intercompany transactions shall be in accordance with the economic terms of any written arrangements among the parties (i.e. liability under the Stand Alone Method shall be computed without regard to any adjustments to such pricing that may be made under Section 482 of the Code or analogous provisions of State or Foreign law); (ii) during Consolidated Periods all computations shall be made in conformity with the positions, elections and accounting methods used by ICN Cabot in preparing the consolidated returns of the ICN Cabot Group; (iii) the highest marginal tax rate to which the Ribapharm CMC Group could be subject under applicable Tax Law shall be deemed to be the only Tax rate to which such group is subject under such law; and (iv) subject to (i) through (iii) above, all computations and other determinations shall be made in accordance with the the laws and regulations applying to affiliated groups filing consolidated returns (including, in the case of any company that becomes or ceases to be a member of any Group, the laws and regulations applicable to a company that becomes or ceases to be a member of a such Group), as well as all other relevant federal Tax laws and regulations (and similar rules shall apply in the case of State or Foreign Taxes in respect to Consolidated or Combined Returns for such Taxes).laws

Appears in 1 contract

Samples: Tax Sharing Agreement (Cabot Microelectronics Corp)

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