Consolidated Return Regulations definition
Examples of Consolidated Return Regulations in a sentence
Except as otherwise provided in Section 5 hereof, all Tax Attributes of the Tridex Group (other than foreign tax credits) will be allocated among Tridex, TransAct and their respective subsidiaries, in accordance with the Regulations promulgated pursuant to Section 1502 of the Code or analogous provisions of state, local or foreign law (the "Consolidated Return Regulations").
The separate Federal income tax liability of each Member with Federal income tax liability for each Tax Period shall first be ascertained under the applicable provisions of the Code and the Consolidated Return Regulations.
If for any taxable year Manor or a Member of the Manor Group recognizes a Tax Attribute which Manor or the Member of the Manor Group, under the applicable provision of the Code and Consolidated Return Regulations is permitted or required to carry back to one of its prior taxable years, Manor or the Member of the Manor Group may file appropriate refund claims and shall be entitled to any refund of Taxes resulting from such claims.
All Tax Attributes of the Sunburst Group will be allocated among Sunburst, Choice, and their respective subsidiaries in accordance with the Regulations promulgated pursuant to Section 1502 of the Code (the "Consolidated Return Regulations") and, to the extent applicable, other provisions of the Code and Regulations (and analogous provisions of state, local, or foreign law).
All Tax Attributes of the Manor Group will be allocated among Manor, Choice, and their respective subsidiaries in accordance with the Regulations promulgated pursuant to Section 1502 of the Code or analogous provisions of state, local, or foreign law (the "Consolidated Return Regulations").
If for any taxable year Tridex or any Member of the Tridex Group recognizes a Tax Attribute which Tridex or such Member of the Tridex Group, under the applicable provision of the Code and Consolidated Return Regulations, carries back to one of its prior taxable years, Tridex or such Member of the Tridex Group may file appropriate refund claims and shall be entitled to any refund resulting from such claims.
The Consolidated Tax Liability of the Group for each Taxable Year of the Group shall, for purposes of determining the earnings and profits of each Member, be allocated among the Members in accordance with the methods prescribed in Section 1.1552-1(a)(2) of the Income Tax Regulations and Section 1.1502-33(d)(3) of the Consolidated Return Regulations.
The fixed percentage to be used for purposes of Section 1.1502-33(d)(3)(i) of the Consolidated Return Regulations shall be 100 percent.
The Income Tax allocation will be exclusive of any gain or loss associated with the distribution of assets, or any other previous intercompany transaction, which will inure to Exxon according to the Consolidated Return Regulations.
Any excess alternative minimum tax liability resulting from the foregoing limitation shall be reallocated among the other Members in accordance with Section 1.1502-33 (d) (2) (i) (b) of the Consolidated Return Regulations.