Tax Equalization. Executive will be provided tax equalization as described in Attachment 1 to help ensure that Executive does not gain or lose financially due to the different tax and social security implications or consequences of Executive’s employment under this Agreement and the Affiliate Agreements. Executive’s burden in respect of the foregoing will remain at a similar level as if Executive were employed solely in Executive’s home country, which for purposes of this agreement is the United States (the “Home Country”). This is achieved by: (i) deducting a “hypothetical tax” from Executive’s total pay related to Executive’s employment with the Company under this Agreement and any Affiliates under the Affiliate Agreements, and (ii) the Company paying Executive’s actual income tax and social taxes on the total income paid to Executive in connection with Executive’s employment with the Company under this Agreement and any Affiliates under the Affiliate Agreements. Notwithstanding anything in this Agreement to the contrary, any payments made to Executive in connection with the foregoing tax equalization shall be made no later than the end of the second taxable year beginning after the taxable year in which Executive’s U.S. Federal income tax return is required to be filed (including any extensions) for the year to which the compensation subject to such tax equalization payment relates, or, if later, the second taxable year beginning after the latest such taxable year in which Executive’s foreign tax return or payment is required to be filed or made for the year to which the compensation subject to the tax equalization payment relates. The tax equalization described in this subsection (a) and in Attachment 1 and all of Executive’s obligations thereunder shall survive the termination of this Agreement.
Appears in 13 contracts
Samples: Employment Agreement, Employment Agreement (Restaurant Brands International Inc.), Employment Agreement (Restaurant Brands International Inc.)
Tax Equalization. Executive will be provided tax equalization as described in Attachment 1 to help ensure that Executive does not gain or lose financially due to the different tax and social security implications or consequences of Executive’s employment under this Agreement and the Affiliate Agreements. Executive’s burden in respect of the foregoing will remain at a similar level as if Executive were employed solely in Executive’s home country, which for purposes of this agreement Agreement is the United States (the “Home Country”). This is achieved by: (i) deducting a “hypothetical tax” from Executive’s total pay related to Executive’s employment with the Company under this Agreement and any Affiliates under the Affiliate Agreements, and (ii) the Company paying Executive’s actual income tax and social taxes on the total income paid to Executive in connection with Executive’s employment with the Company under this Agreement and any Affiliates under the Affiliate Agreements. Notwithstanding anything in this Agreement to the contrary, any payments made to Executive in connection with the foregoing tax equalization shall be made no later than the end of the second taxable year beginning after the taxable year in which Executive’s U.S. Federal income tax return is required to be filed (including any extensions) for the year to which the compensation subject to such tax equalization payment relates, or, if later, the second taxable year beginning after the latest such taxable year in which Executive’s foreign tax return or payment is required to be filed or made for the year to which the compensation subject to the tax equalization payment relates. The tax equalization described in this subsection (a) and in Attachment 1 and all of Executive’s obligations thereunder shall survive the termination of this Agreement.
Appears in 8 contracts
Samples: Employment Agreement (Restaurant Brands International Inc.), Employment Agreement (Restaurant Brands International Inc.), Employment Agreement (Restaurant Brands International Inc.)
Tax Equalization. Executive You will be provided tax equalization as described in Attachment 1 Exhibit “B” to help ensure that Executive does you do not gain or lose financially due to the different tax and social security implications or consequences of Executive’s employment under this Agreement and the Affiliate AgreementsAssignment. Executive’s Your burden in respect of the foregoing will remain at a similar level as if Executive were employed solely in Executive’s home country, which for purposes of this agreement is the United States (the “Home Country”)Assignment had not taken place. This is achieved by: (i) by deducting a “hypothetical tax” from Executive’s total your pay related to Executive’s employment with the Company under this Agreement and any Affiliates under the Affiliate Agreements, and (ii) the Company paying Executive’s your actual income tax and social taxes on the total income paid to Executive your Company income. The designated tax service consultant will explain tax equalization in connection with Executive’s employment with the Company under this Agreement and any Affiliates under the Affiliate Agreementsmore detail during your tax consultations. Notwithstanding anything in this Agreement Assignment Letter to the contrary, any payments made to Executive you in connection with the foregoing tax equalization shall be made no later than the end of the your second taxable year beginning after the taxable year in which Executive’s your U.S. Federal income tax return is required to be filed (including any extensions) for the year to which the compensation subject to such tax equalization payment relates, or, if later, the your second taxable year beginning after the latest such taxable year in which Executive’s your foreign tax return or payment is required to be filed or made for the year to which the compensation subject to the tax equalization payment relates. The tax equalization described in this subsection (a) and in Attachment 1 Exhibit “B” and all of Executive’s your obligations thereunder shall survive the termination of this AgreementAssignment Letter and your Assignment.
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