Tax Treatment of the Transaction. The Parties intend that the Transaction will be treated for U.S. federal income tax purposes as set forth in this Section 5.3 (the “Intended Tax Treatment”). Each party shall, and shall cause its controlled Affiliates to, file all tax returns and other reports consistent with the Intended Tax Treatment, unless required by Law to do otherwise.
Appears in 3 contracts
Samples: Partnership Interests Restructuring Agreement (MPLX Lp), Partnership Interests Restructuring Agreement (Marathon Petroleum Corp), Partnership Interests Restructuring Agreement (Marathon Petroleum Corp)
Tax Treatment of the Transaction. The Parties intend that the Transaction transactions described in Section 2.1 and Section 2.2 will be treated for U.S. federal income tax purposes as set forth in this Section 5.3 (the “Intended Tax Treatment”). Each party Party shall, and shall cause its controlled Affiliates to, file all tax Tax returns and other reports consistent with the Intended Tax Treatment, unless required by Law to do otherwise.
Appears in 1 contract
Samples: Partnership Interests Restructuring Agreement (Shell Midstream Partners, L.P.)