Year of IPO. For purposes of this Agreement, the taxable year that includes the date of this Agreement shall be treated as if it were comprised of two taxable periods, one of which ends on the date of this Agreement and one of which begins on the day after the date of this Agreement. For purposes of computing the Federal Taxes attributable to each period of the taxable year, the amount of any item that is taken into account only once for each taxable year (e.g., the benefit of graduated tax rates, exemption amounts, etc.) shall be allocated between the two portions of the year in proportion to the number of days in each portion. To the extent needed under this Agreement, the WhiteWave Group Federal Income Tax Liability shall be determined separately for each period.
Appears in 4 contracts
Samples: Tax Matters Agreement (Dean Foods Co), Tax Matters Agreement (WHITEWAVE FOODS Co), Tax Matters Agreement (WHITEWAVE FOODS Co)
