Examples of Carryback Item in a sentence
If the Carryback Period of a Circor Carryback Item ---------- includes a taxable period subject to a Return filed by Xxxxx under Section 7.01(a), Circor shall elect (under Code Section 172(b)(3) and (f)(6) and any other applicable Code provision and, to the extent feasible, any similar provision of applicable state or local Income Tax law) to relinquish such Carryback Period unless the parties agree otherwise.
With respect to any Tax imposed on or attributable to any Group Member for any applicable Pre-IPO Period, Parent may make an Adjustment Request with respect to such Tax, including carrying back a Carryback Item of any Parent Group Member arising in a Post-IPO Period to any Pre-IPO Period.
Notwithstanding Section 4.5(a), if any Cal Dive Group Member is required by applicable Tax Law to carry back a Carryback Item arising in a Post-IPO Period to a Pre-IPO Period, the Companies agree that any Carryback Item of any Parent Group Member that may be carried back to the same Pre-IPO Period shall be deemed to be used before any Carryback Item of any Cal Dive Group Member.
With respect to any Tax imposed on or attributable to any Group Member for any applicable Pre-Deconsolidation Period, Distributing may make an Adjustment Request with respect to such Tax, including carrying back a Carryback Item of any Distributing Group Member arising in a Post-Deconsolidation Period to any Pre-Deconsolidation Period.
Treasury Regulation 1.1502-21 or any successor provision shall govern the ordering and priority of utilization of any carryback item, including any Ventures Carryback Item, to any return filed by the Consolidated Group.