Electronics Business Tax Attribute definition
Electronics Business Tax Attribute means any Tax Attribute of any Electronics Entity attributable to the Electronics Business, as determined by ▇▇▇▇▇▇▇ Controls in good faith.
Electronics Business Tax Attribute means any Tax Attribute of any Electronics Entity attributable to the Electronics Business, as determined by ▇▇▇▇▇▇▇ Controls in good faith. “Electronics Entity” means each of ▇▇▇▇▇▇▇ Controls Automotive Electronics do Brasil Ltda. (formerly SAGEM Do Brasil), JC International ZAO, and any of their respective successors. “Employee Matters Agreement” means the Employee Matters Agreement, dated as of September 8, 2016, by and between ▇▇▇▇▇▇▇ Controls and Adient. “Federal Income Tax” means any Tax imposed by Subtitle A of the Code. “Federal Other Tax” means any Tax imposed by the federal government of the United States of America other than any Federal Income Taxes. “Fifty-Percent or Greater Interest” has the meaning ascribed to such term for pur- poses of Sections 355(d) and (e) of the Code and the Treasury Regulations Thereunder. “Filing Date” has the meaning set forth in Section 6.04(d). “Final Determination” means the final resolution of liability for any Tax, which resolution may be for a specific issue or adjustment or for a Tax Period, (a) by IRS Form 870 or 870-AD (or any successor forms thereto), on the date of acceptance by or on behalf of the tax- payer, or by a comparable form under the Laws of a State, local or foreign taxing jurisdiction, except that a Form 870 or 870-AD or comparable form shall not constitute a Final Determination to the extent that it reserves (whether by its terms or by operation of Law) the right of the tax- payer to file a claim for Refund or the right of the Tax Authority to assert a further deficiency in respect of such issue or adjustment or for such Tax Period (as the case may be); (b) by a deci- sion, judgment, decree or other order by a court of competent jurisdiction, which has become fi- nal and unappealable; (c) by a closing agreement or accepted offer in compromise under Section 7121 or 7122 of the Code, or a comparable agreement under the Laws of a State, local or foreign taxing jurisdiction; (d) by any allowance of a Refund in respect of an overpayment of Tax, but
Electronics Business Tax Attribute means any Tax Attribute of any Electronics Entity attributable to the Electronics Business, as determined by Johnson Controls in good faith.