Pre-Distribution Period definition

Pre-Distribution Period means any Tax Period ending on or before the Distribution Date, and, in the case of any Straddle Period, the portion of such Straddle Period ending on the Distribution Date.

Pre-Distribution Period means any Tax Year or other taxable period that ends on or before the Distribution Date and, in the case of any Straddle Period, that part of the Tax Year or other taxable period through the end of the day on the Distribution Date.

Pre-Distribution Period means any Tax Period ending on or before the Distribution Date and, in the case of any Straddle Period, the portion of such Straddle Period ending on the Distribution Date.

Examples of Pre-Distribution Period in a sentence

• As promptly as practicable following the close of the taxable year in which the Distribution occurs, Distributing shall deliver to Splitco its determination in writing of the amount of any Tax Attributes arising in a Pre-Distribution Period which are allocated or apportioned to the members of the Splitco Group in accordance with applicable Tax Law and this Agreement (“Proposed Allocation”).

• Subject to Section 9.2(c) and Section 9.2(d) of this Agreement, CURB shall have reasonable discretion, after consultation with SITC, with respect to any decisions to be made, or the nature of any action to be taken, with respect to any such Tax Contest relating to a CURB Separate Return for a Pre-Distribution Period or Straddle Period, and absolute discretion with respect to any decisions to be made, or the nature of any action to be taken, with respect to any other such Tax Contest.

• Distributing shall have the sole discretion of filing any Tax Return on a consolidated, combined, or unitary basis, if such Tax Return would include at least one member of each Group (or with respect to any Pre-Distribution Period, Tax Items of both the Distributing Business and the Splitco Business) and the filing of such Tax Return is elective under applicable Tax Law.

• Splitco shall, to the extent permitted by applicable Tax Law, make any available elections to waive the right to carry back any Tax Item attributable to or arising from the Splitco Business from a Tax Period beginning after the Distribution Date to a Tax Period beginning in the Pre-Distribution Period and shall not make any affirmative elections to carry back any such Tax Item.

More Definitions of Pre-Distribution Period

Pre-Distribution Period means any Taxable period (or portion thereof) ending on or before the Distribution Date.

Pre-Distribution Period means all taxable periods (or portions thereof) ending before or at the Effective Time.

Pre-Distribution Period means any Tax Period (or portion thereof) ending on or before the Distribution Date, including, for the avoidance of doubt, the portion of any Straddle Period with respect to the Distribution Date ending at the end of the day on the Distribution Date.

Pre-Distribution Period means any taxable period (or portion thereof) ending on or before the close of business on the Distribution Date.

Pre-Distribution Period means any Taxable period ending on or before the close of business on the Distribution Date; provided that if a Taxable period ending after the Distribution Date contains any days which fall prior to or on the Distribution Date, any portion of such Taxable period up to and including the Distribution Date shall also be included in the Pre-Distribution Period.

Pre-Distribution Period means the period of time from the date hereof until completion of the Distribution.

Pre-Distribution Period means the period of time from the date hereof until the completion of the Distribution.