Transaction Taxes and Transaction Tax-Related Losses. (i) Distributing shall be allocated all Transaction Taxes and Transaction Tax-Related Losses other than any Transaction Taxes and Transaction Tax-Related Losses allocated to Splitco pursuant to clause (ii) of this Section 2.2(b). (ii) Splitco shall be allocated any Transaction Taxes and Transaction Tax-Related Losses that (x) result primarily from, individually or in the aggregate, any breach by Splitco of any of its covenants set forth in Section 7.1 hereof, or (y) result from a Splitco Section 355(e) Event.
Appears in 4 contracts
Samples: Tax Sharing Agreement (Gci Liberty, Inc.), Tax Sharing Agreement (General Communication Inc), Tax Sharing Agreement (Liberty Interactive Corp)
Transaction Taxes and Transaction Tax-Related Losses. (i) Distributing shall be allocated all Transaction Taxes and Transaction Tax-Related Losses other than any Transaction Taxes and Transaction Tax-Related Losses allocated to Splitco pursuant to clause (ii) of this Section 2.2(b).
(ii) Splitco shall be allocated any Transaction Taxes and Transaction Tax-Related Losses that (x) result primarily from, individually or in the aggregate, any breach by Splitco of any of its covenants set forth in Section 7.1 hereof, or (y) result from a Splitco Section 355(e) Event, or (z) result from any ELA in the Splitco Stock or gain recognized under Section 361(b) of the Code as a result of the basis limitation described in the last sentence of Section 361(b)(3) of the Code.
Appears in 4 contracts
Samples: Tax Sharing Agreement (Liberty Media Corp), Tax Sharing Agreement (Liberty Media Corp), Tax Sharing Agreement (Atlanta Braves Holdings, Inc.)
