Transactions Treated as Extraordinary Items. In determining the apportionment of Tax Items between Pre-Closing Periods and Post-Closing Periods, any Tax Items relating to the Transactions shall be treated as extraordinary items described in Treasury Regulation Section 1.1502-76(b)(2)(ii)(C) and shall (to the extent occurring on or prior to the Closing Date) be allocated to Pre-Closing Periods, and any Taxes related to such items shall be treated under Treasury Regulation Section 1.1502-76(b)(2)(iv) as relating to such extraordinary items and shall (to the extent occurring on or prior to the Closing Date) be allocated to Pre-Closing Periods.
Appears in 5 contracts
Samples: Tax Matters Agreement (Ocwen Financial Corp), Tax Matters Agreement (Brink's Home Security Holdings, Inc.), Tax Matters Agreement (Altisource Portfolio Solutions S.A.)
Transactions Treated as Extraordinary Items. In determining the apportionment of Tax Items between Pre-Closing Separation Periods and Post-Closing Separation Periods, any Tax Items relating to the Separation Transactions shall be treated as extraordinary items described in Treasury Regulation Regulations Section 1.1502-76(b)(2)(ii)(C) and shall (to the extent occurring on or prior to the Closing Effective Date) be allocated to Pre-Closing Separation Periods, and any Taxes related to such items shall be treated under Treasury Regulation Regulations Section 1.1502-76(b)(2)(iv) as relating to such extraordinary items item and shall (to the extent occurring on or prior to the Closing Effective Date) be allocated to Pre-Closing Separation Periods.
Appears in 1 contract
Samples: Tax Matters Agreement (Screaming Eagle Acquisition Corp.)
