Treatment of Payments. Unless otherwise required by any Final Determination, the Parties agree that any payments made by one Party to the other Party (other than payments of interest pursuant to Section 6.5 and payments of After Tax Amounts pursuant to Section 6.4) pursuant to this Agreement shall be treated for all Tax purposes as nontaxable payments made immediately prior to the Distribution and, accordingly not includible in the taxable income of the recipient.
Appears in 4 contracts
Samples: Tax Sharing Agreement (United Online Inc), Tax Sharing Agreement (FTD Companies, Inc.), Tax Sharing Agreement (FTD Companies, Inc.)
Treatment of Payments. Unless otherwise required by any Final Determination, the Parties agree that any payments made by one Party to the other another Party (other than payments of interest pursuant to Section 6.5 8.04(e) of this Agreement and payments of After After-Tax Amounts pursuant to Section 6.48.04(d) of this Agreement) pursuant to this Agreement shall to the extent permissible under applicable law be treated for all Tax and financial accounting purposes as nontaxable payments made immediately prior to the Distribution and, accordingly accordingly, as not includible in the taxable income of the recipientrecipient or as deductible by the payor.
Appears in 3 contracts
Samples: Tax Sharing Agreement (TreeHouse Foods, Inc.), Tax Sharing Agreement (Dean Foods Co/), Tax Sharing Agreement (TreeHouse Foods, Inc.)
Treatment of Payments. Unless otherwise required by any Final Determination, the Parties agree that any payments made by one Party to the other Party (other than payments of interest pursuant to Section 6.5 and payments of After Tax Amounts pursuant to Section 6.4) pursuant to this Agreement shall be treated for all Tax and financial accounting purposes as nontaxable payments (dividend distributions or capital contributions, as the case may be) made immediately prior to the Distribution and, accordingly not includible in the taxable income of the recipient.
Appears in 3 contracts
Samples: Tax Sharing Agreement (A & B II, Inc.), Tax Sharing Agreement (Alexander & Baldwin Inc), Tax Sharing Agreement (A & B II, Inc.)
Treatment of Payments. Unless otherwise required by any Final Determination, the Parties agree that any payments made by one Party party to the other Party another party (other than payments of interest pursuant to Section 6.5 4.1(e) and payments of After Tax Amounts pursuant to Section 6.44.1(d)) pursuant to this Agreement shall be treated for all Tax and financial accounting purposes as nontaxable payments (dividend distributions or capital contributions, as the case may be) made immediately prior to the Distribution and, accordingly accordingly, as not includible in the taxable income of the recipient.
Appears in 3 contracts
Samples: Tax Sharing Agreement (Cendant Corp), Tax Sharing Agreement (PHH Corp), Tax Sharing Agreement (PHH Corp)
Treatment of Payments. Unless otherwise required by any Final Determination, the Parties parties agree that any payments made by one a Liable Party to the other Other Party (other than payments of interest pursuant to Section 6.5 and payments of After Tax Amounts pursuant to Section 6.4) pursuant to this Tax Separation Agreement shall be treated for all Tax and financial accounting purposes as nontaxable payments made immediately prior to the Distribution and, accordingly not includible in the taxable income of the recipientDistribution.
Appears in 2 contracts
Samples: Tax Separation Agreement (Pioneer Group Inc), Tax Separation Agreement (Harbor Global Co LTD)
Treatment of Payments. Unless otherwise required by any Final Determination, the Parties agree that any payments made by one Party to the other Party (other than payments of interest pursuant to Section 6.5 and payments of After Tax Amounts pursuant to Section 6.4) pursuant to this Agreement shall be treated for all Tax purposes as nontaxable payments made immediately prior to the Distribution and, accordingly not includible in the taxable income of the recipientDistribution.
Appears in 2 contracts
Samples: Tax Matters Agreement (Theravance Inc), Tax Matters Agreement (Theravance Biopharma, Inc.)
Treatment of Payments. Unless otherwise required by law or under any Final Determination, the Parties parties agree that any payments made by one Party party to the other Party another party (other than payments of interest pursuant to Section 6.5 5.1(e) and payments of After Tax Amounts pursuant to Section 6.45.1(d)) pursuant to this Agreement shall be treated for all Tax and financial accounting purposes as nontaxable payments (dividend distributions or capital contributions, as the case may be) made immediately prior to the Distribution Separation and, accordingly accordingly, as not includible in the taxable income of the recipient.
Appears in 2 contracts
Samples: Tax Sharing Agreement (NTL Inc), Tax Sharing Agreement (NTL Europe Inc)
Treatment of Payments. Unless otherwise required by any Final Determination, the Parties parties agree that any payments made by one Party party to the other Party another party (other than payments of interest pursuant to Section 6.5 and payments of After Tax Amounts pursuant to Section 6.4) pursuant to this Agreement shall be treated for all Tax and financial accounting purposes as nontaxable payments (dividend distributions or capital contributions, as the case may be) made immediately prior to the Distribution Spin-offs and, accordingly not includible in the taxable income of the recipient.
Appears in 2 contracts
Samples: Tax Sharing Agreement (Clearwater Paper Corp), Tax Sharing Agreement (Potlatch Forest Products CORP)
Treatment of Payments. Unless otherwise required by any Final Determination, the Parties agree that any payments made by one Party to the other another Party (other than payments of interest pursuant to Section 6.5 12.03(e) and payments of After Tax Amounts pursuant to Section 6.412.03(d)) pursuant to this Agreement shall be treated for all Tax and financial accounting purposes as nontaxable payments (dividend distributions or capital contributions, as the case may be) made immediately prior to the Distribution and, accordingly accordingly, as not includible in the taxable income of the recipient.
Appears in 1 contract
Treatment of Payments. Unless otherwise required by any Final Determination, the Parties parties agree that any payments made by one Party party to the other Party another party (other than payments of interest pursuant to Section 6.5 6.3(e) and payments of After Tax Amounts pursuant to Section 6.46.3(d)) pursuant to this Agreement shall be treated for all Tax and financial accounting purposes as nontaxable payments (dividend distributions or capital contributions, as the case may be) made immediately prior to the Distribution and, accordingly accordingly, as not includible in the taxable income of the recipient.
Appears in 1 contract
Samples: Tax Sharing Agreement (Coach Inc)