Transaction Taxes and Transaction Tax-Related Losses. Notwithstanding any other provision in this Section 2: (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 Spinco pursuant to clause (ii) of this Section 2.2(a). (ii) Spinco will be allocated any Transaction Taxes (including corresponding state and local Taxes) and Transaction Tax-Related Losses that (x) result primarily from, individually or in the aggregate, any breach by Spinco of any of its covenants set forth in Section 7.1 hereof, or (y) result from a Spinco Section 355(e) Event.
Appears in 6 contracts
Samples: Tax Sharing Agreement (CommerceHub, Inc.), Tax Sharing Agreement (CommerceHub, Inc.), Tax Sharing Agreement (Liberty Broadband Corp)
