Tax Effects of Indemnification. (a) Any indemnification payment made under this Agreement shall be characterized for tax purposes as if such payment were made immediately prior to the Distribution Date, and shall therefore be treated, to the extent permitted by law, as either (i) a distribution from Direct Alliance to Insight or (ii) a capital contribution from Insight to Direct Alliance.
Appears in 1 contract
Samples: Separation and Distribution Agreement (Direct Alliance Corp)
Tax Effects of Indemnification. (a) Any indemnification payment made under this Agreement shall be characterized for tax purposes as if such payment were made immediately prior to the latest Distribution Date, and shall therefore be treated, to the extent permitted by law, as either (i) a distribution from Direct Alliance GameStop to Insight Barnes & Noble or (ii) a capital contribution from Insight Barnes & Noble to Direct AllianceXxxxXxop.
Appears in 1 contract
Samples: Separation Agreement (Gamestop Corp)
Tax Effects of Indemnification. (a) Any indemnification payment made under this Agreement shall be characterized for tax purposes as if such payment were made immediately prior to the latest Distribution Date, and shall therefore be treated, to the extent permitted by law, as either (i) a distribution from Direct Alliance OSCA to Insight GLC or (ii) a capital contribution from Insight GLC to Direct AllianceOSCA.
Appears in 1 contract
Tax Effects of Indemnification. (a) Any indemnification payment made under this Agreement shall be characterized for tax purposes as if such payment were made immediately prior to the latest Distribution Date, and shall therefore be treated, to the extent permitted by law, as either (i) a distribution from Direct Alliance PFSweb to Insight Daisytek or (ii) a capital contribution from Insight Daisytek to Direct AlliancePFSweb.
Appears in 1 contract
Samples: Initial Public Offering and Distribution Agreement (Daisytek International Corporation /De/)
Tax Effects of Indemnification. (a) Any indemnification payment made under this Agreement shall be characterized for tax purposes as if such payment were made immediately prior to the Distribution Date, and shall therefore be treated, to the extent permitted by law, as either (i) a distribution from Direct Alliance Holdings to Insight Continental or (ii) a capital contribution from Insight Continental to Direct AllianceHoldings.
Appears in 1 contract
Samples: Offering and Distribution Agreement (Expressjet Holdings Inc)
