Examples of Parent Consolidated Return in a sentence
All calculations of deemed refunds pursuant to this Section 5 shall include interest computed as if the Subsidiary Consolidated Group had filed a claim for refund or an application for a tentative carryback adjustment pursuant to Section 6411(a) of the Code on the date on which the relevant Parent Consolidated Return is filed.
The Pro Forma Subsidiary Return shall be prepared in a manner that reflects all elections, positions and methods used in the Parent Consolidated Return that must be applied on a consolidated basis and otherwise shall be prepared in a manner consistent with the Parent Consolidated Return.
To the extent that there is a Final Determination with respect to a Parent Consolidated Return that results in a change in an item relating to such return (an “Adjustment”) that affects the treatment of a Subsidiary Return Item for an Agreement Year, a corresponding adjustment shall be made to the corresponding Pro Forma Subsidiary Return.
Any refund of Consolidated Taxes received from a Taxing Authority by any member of the HERC Parent Group or the RAC Parent Group with respect to a HERC Parent Consolidated Return shall be the property of the HERC Parent Group, except to the extent that such Tax refund relates to any Taxes for which the RAC Parent Group is responsible under this Agreement.
The Agreement shall remain in force and be binding so long as the applicable period of assessments (including extensions) remains unexpired for any taxes contemplated by the Agreement; provided, however, that neither Parent nor the Subsidiaries shall have any liability to the other party with respect to tax liabilities for any taxable year in which the Subsidiary Consolidated Group is not included in the Parent Consolidated Return for such year, except as provided in Sections 5 and 10.
If for any taxable year the Subsidiary is no longer included in the Parent Consolidated Group, Parent and the Subsidiary agree to provide to the other party any information reasonably required to complete tax returns for taxable periods beginning after the Subsidiary is no longer included in a Parent Consolidated Return, and each of Parent and the Subsidiary will cooperate with respect to any audits or litigation relating to any Parent Consolidated Return.
If the Total Periodic Payments to Parent for any Agreement Year exceed the amount of the liability of the Subsidiary for such Agreement Year under the preceding sentence, Parent shall pay to the Subsidiary an amount equal to such excess within 10 days after filing the Parent Consolidated Return for such Agreement Year.
In the event that any dispute is not resolved (whether pursuant to good faith negotiations among the Parties or by the Accounting Firm) prior to the Due Date for the filing of any Parent Consolidated Return, such Parent Consolidated Return shall be timely filed by Parent and the Parties agree to amend such Parent Consolidated Return as necessary to reflect the resolution of such dispute in a manner consistent with such resolution.
If for any taxable year the Subsidiaries are no longer included in the Parent Consolidated Group, Parent and the Subsidiaries agree to provide to the other party any information reasonably required to complete tax returns for taxable periods beginning after the Subsidiaries are no longer included in a Parent Consolidated Return, and each of Parent and the Subsidiaries will cooperate with respect to any audits or litigation relating to any Parent Consolidated Return.
The Subsidiary shall provide to Parent, in a format determined by Parent, all information requested by Parent as reasonably necessary to prepare the Parent Consolidated Return and the Pro Forma Subsidiary Return (the “Subsidiary Tax Package”).