Transactions Treated as Extraordinary Item. In determining the apportionment of Tax Items between Pre-Distribution Periods and Post-Distribution Periods, any Tax Items relating to the Separation Transactions shall be treated as extraordinary items described in Treasury Regulations Section 1.1502-76(b)(2)(ii)(C) and shall (to the extent occurring on or prior to the External Distribution Date) be allocated to Pre-Distribution Periods, and any Taxes related to such items shall be treated under Treasury Regulations Section 1.1502-76(b)(2)(iv) as relating to such extraordinary item and shall (to the extent occurring on or prior to the External Distribution Date) be allocated to Pre-Distribution Periods.
Appears in 4 contracts
Samples: Tax Matters Agreement (EQT Corp), Tax Matters Agreement (Equitrans Midstream Corp), Tax Matters Agreement (Equitrans Midstream Corp)
