Covered Group Return definition

Covered Group Return means any Tax Return (including any consolidated, combined, or unitary Tax Return) that includes both Alpha Taxes and Generico Taxes for a period that ends prior to or includes the Distribution Date.
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Covered Group Return means any Tax Return (including any consolidated, combined or unitary Tax Return) that includes one or more members of both the SpinCo Group and the Sabra Group for a period that ends prior to or includes the Distribution Date.
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Examples of Covered Group Return in a sentence

  • Unless the parties otherwise agree in writing, the Alpha Parties and the Generico Parties shall elect and shall cause each of the Alpha Subsidiaries or Generico Subsidiaries to elect, where permitted by Applicable Laws, to carry forward any loss, credit or similar Tax attribute arising in a Post-Distribution Period, with respect to a Covered Group Return (“Tax Carryover Attribute”) that could, in the absence of such election, be carried back to a Pre-Distribution Period.

  • Unless the parties otherwise agree in writing, SpinCo shall be permitted (but not required), where permitted by Applicable Laws, to carryback any loss, credit or similar Tax Attribute arising in a Post-Distribution Period, with respect to a Covered Group Return (“Tax Carryback Attribute”) to a Pre-Distribution Period; provided that Sabra will not suffer any unindemnified adverse tax consequences, and provided further that such refund shall not adversely affect Sabra’s REIT status.

  • Any refund or credit of Taxes resulting from the required carryback to a Covered Group Return of any Tax Carryover Attribute arising in a Post-Distribution Period shall be for the account and benefit of SpinCo. Sabra shall cooperate with all reasonable requests from SpinCo in connection with this Section 2.07.

  • Unless the parties otherwise agree in writing, SpinCo and the ABI Parties shall elect and shall cause each of the SpinCo Subsidiaries to elect, where permitted by Applicable Laws, to carry forward any loss, credit or similar Tax attribute arising in a Post-Distribution Period, with respect to a Covered Group Return (“Tax Carryover Attribute”) that could, in the absence of such election, be carried back to a Pre-Distribution Period.

  • Any refund or credit of Taxes resulting from the required carryback to a Covered Group Return of any Tax Carryover Attribute attributable to the SpinCo Business arising in a Post-Distribution Period shall be for the account and benefit of SpinCo. Any refund, credit or offset of Taxes resulting from the carryback of any Tax Carryover Attribute attributable to the ABI Business arising in a Post-Distribution Period shall be for the account and benefit of the ABI Parties.

Related to Covered Group Return

  • Joint Return means any Return of a member of the Parent Group or the SpinCo Group that is not a Separate Return.

  • Combined Return means any Tax Return (other than for Federal Income Taxes) filed on a consolidated, combined (including nexus combination, worldwide combination, domestic combination, line of business combination or any other form of combination), unitary or Group Relief basis that includes activities of members of the ESG Group or the KBR Group, or both, as the case may be.

  • Separate Return means (a) in the case of any Tax Return of any member of the SpinCo Group (including any consolidated, combined or unitary return), any such Tax Return that does not include any member of the Parent Group and (b) in the case of any Tax Return of any member of the Parent Group (including any consolidated, combined or unitary return), any such Tax Return that does not include any member of the SpinCo Group.

  • Consolidated Return means any Tax Return relating to Income Taxes filed pursuant to Section 1502 of the Code, or any comparable combined, consolidated, or unitary group Tax Return relating to Income Taxes filed under state or local tax law which, in each case, includes IDT and at least one subsidiary.

  • Current Return means the minimum fair combined rate of return on common equity required for

  • Combined Group means a group of corporations or other entities that files a Combined Return.

  • SpinCo Separate Return means any Tax Return of or including any member of the Spinco Group (including any consolidated, combined, or unitary return) that does not include any member of the Remainco Group.

  • Priority Return means a 6% cumulative, non-compounded, pre-tax annual return (based on a 365-day year).

  • Investment Return means the investment return payable in respect of the Bond in accordance with Clause 5 Returns.

  • Preferred Return has the meaning specified in the Company LLC Agreement.

  • Net Economic Return shall have the meaning ascribed to such term in paragraph 2 of Exhibit E to the Lease.

  • Corporate Taxpayer Return means the federal and/or state and/or local Tax Return, as applicable, of the Corporate Taxpayer filed with respect to Taxes of any Taxable Year.

  • Company Returns is defined in Section 3.15(a) of the Agreement.

  • annual return means the return required to be made in the case of a company having a share capital, under section 132 and in the case of a company not having a share capital, under section 133;

  • Hypothetical Tax Liability means, with respect to any Taxable Year, the Hypothetical Federal Tax Liability for such Taxable Year, plus the Hypothetical Other Tax Liability for such Taxable Year.

  • Pre-Tax Contributions means, for any Participant, the aggregate of the Participant's Basic Pre-Tax Contributions and Supplemental Pre-Tax Contributions contributed to the applicable Pre-Tax Contribution Account.

  • Target Capital Account means the Capital Account of a Member as of the end of each fiscal year, increased by any amount that such Member is obligated to restore under this Agreement, is treated as obligated to restore under Treasury Regulations Section 1.704-1(b)(2)(ii)(c), or is deemed obligated to restore under the penultimate sentences of Treasury Regulations Section 1.704-2(g)(1) and (i)(5).

  • Pre-Tax Earnings means the Corporation's earnings before income taxes as reported in the Company's Consolidated Income Statement for each fiscal year of the Performance Period, excluding any non-cash charge incurred in accordance with accounting principles generally accepted in the United States of America (GAAP) for any restricted stock or restricted stock unit awards granted during the Performance Period and all options, restricted stock and other equity compensation granted to Directors during the Performance Period.

  • Post-Distribution Tax Period means a Tax year beginning and ending after the Distribution Date.

  • Permitted Group means any group of investors that is deemed to be a "person" (as that term is used in Section 13(d)(3) of the Exchange Act), by virtue of the Stockholders Agreement, as the same may be amended, modified or supplemented from time to time; provided that no single Person (other than the Principals and their Related Parties) Beneficially Owns (together with its Affiliates) more of the Voting Stock of the Company that is Beneficially Owned by such group of investors than is then collectively Beneficially Owned by the Principals and their Related Parties in the aggregate.

  • Tax Distribution Date has the meaning set forth in Section 4.01(b)(i).

  • Distribution Period means, for any Distribution Date, the period from and including the Distribution Date immediately preceding such Distribution Date (or, in the case of the first Distribution Date, from and including the Closing Date) to but excluding such Distribution Date.

  • Related Group For Loan Group 1, Group 1 and for Loan Group 2, Group 2.

  • Net After-Tax Benefit means the Present Value of a Payment net of all federal state and local income, employment and excise taxes imposed on Executive with respect thereto, determined by applying the highest marginal rate(s) applicable to an individual for Executive’s taxable year in which the Change in Control occurs.

  • Non-Income Tax Return means any Tax Return relating to Taxes other than Income Taxes.

  • Controlled Group Liability means any and all liabilities (i) under Title IV of ERISA, (ii) under Section 302 of ERISA, (iii) under Sections 412 and 4971 of the Code, (iv) as a result of a failure to comply with the continuation coverage requirements of Section 601 et seq. of ERISA and Section 4980B of the Code, and (v) under corresponding or similar provisions of foreign laws or regulations.