Tax-Timing Adjustments. To the extent that any portion of any Tax Liability (or Tax benefit) allocated under Section 2.1 relates to a Tax-timing Adjustment, that portion of such Tax Liability (or Tax benefit) shall be allocated to the entity that will receive the benefit (or detriment) of that Tax-timing Adjustment. For purposes of this Agreement, the fact that the period or periods in which offsetting Adjustments will arise is unknown or not determinable shall not be taken into account.
Appears in 6 contracts
Samples: Tax Separation Agreement (dELiAs, Inc.), Tax Separation Agreement (dELiAs, Inc.), Tax Sharing Agreement (Us West Inc)