Treatment of Payments. The Parties agree that any payment made between the Parties pursuant to this Agreement or any other Ancillary Agreement with respect to a Pre-Distribution Period or as a result of an event or action occurring in a Pre-Distribution Period shall be treated, to the extent permitted by law, for all Tax purposes as a nontaxable payment (i.e., a distribution or a capital contribution) made immediately prior to the Distribution.
Appears in 8 contracts
Samples: Tax Sharing Agreement (Parametric Sound Corp), Tax Sharing Agreement (LRAD Corp), Tax Sharing Agreement (Parametric Sound Corp)
Treatment of Payments. The Parties agree that any payment made between the Parties pursuant to this Agreement or any other Ancillary Transaction Agreement with respect to a Pre-Distribution Period or as a result of an event or action occurring in a Pre-Distribution Period shall be treated, to the extent permitted by law, for all Tax purposes as a nontaxable payment (i.e., a distribution or a capital contribution) made immediately prior to the Distribution.
Appears in 2 contracts
Samples: Tax Sharing Agreement (Idearc Inc.), Tax Sharing Agreement (Idearc Inc.)
Treatment of Payments. The Parties agree that any payment made between the Parties pursuant to this Agreement or any other Ancillary Agreement with respect to a Pre-Distribution Period or as a result of an event or action occurring in a Pre-Distribution Period shall be treated, to the extent permitted by law, for all Tax purposes as a nontaxable payment (i.e., a distribution or a capital contribution) made immediately prior to the Distribution as made pursuant to an obligation existing between the Parties as of the Distribution.
Appears in 2 contracts
Samples: Tax Sharing Agreement (Furiex Pharmaceuticals, Inc.), Tax Sharing Agreement (Furiex Pharmaceuticals, Inc.)
Treatment of Payments. The Parties agree that any payment made between the Parties pursuant to this Agreement, the Separation Agreement or any other Ancillary Agreement with respect to a Pre-Distribution Redemption Period or as a result of an event or action occurring in a Pre-Distribution Redemption Period shall be treated, to the extent permitted by law, for all Tax purposes as a nontaxable payment (i.e., a distribution or a capital contribution) made immediately prior to the DistributionRedemption.
Appears in 2 contracts
Samples: Tax Matters Agreement (Sizmek Inc.), Tax Matters Agreement (New Online Co)
