Pre-Distribution Tax Period definition

Pre-Distribution Tax Period means any taxable period (or portion thereof) that ends on or before the Distribution Date.

Pre-Distribution Tax Period means any Tax period ending on or before the Distribution Date.

Pre-Distribution Tax Period means any taxable period ending on or before the close of the Distribution Date and the portion of any Straddle Period ending on the Distribution Date.

Examples of Pre-Distribution Tax Period in a sentence

• Personnel files contain documents relating to employee performance, documents related to decisions made about the employee, and other documents related to the administration of Agency personnel.

• If a Tax Return of any member of the SpinCo Group for any taxable period ending after the Distribution Date reflects any net operating loss, net capital loss, excess Tax credit or other Tax attribute (a “Tax Attribute”), then the applicable member of the SpinCo Group shall waive the right to carry back any such Tax Attribute to a Tax Return described in Section 3.01(a) for a Pre-Distribution Tax Period to the extent permissible under applicable Law.

• Notwithstanding the foregoing, in the event a Refund is the result of the carryback by a Party (or one of such Party’s Affiliates) of a Tax Attribute generated in a Post-Distribution Tax Period or a Straddle Tax Period to a Pre-Distribution Tax Period or a Straddle Tax Period permitted pursuant to Section 4.2 solely because such carryback cannot result in one or more other Parties (or their Affiliates) being liable for additional Taxes, such Refund shall not be shared with any other Party.

• Each of the Parties shall be permitted (but not required) to carryback (or to cause its Subsidiaries to carryback) a Tax Attribute realized in a Post-Distribution Tax Period or a Straddle Tax Period to a Pre-Distribution Tax Period or a Straddle Tax Period only if such carryback cannot reasonably result in the other Party (or its Subsidiaries) being liable for additional Taxes.

• Sales and Use Tax Returns for the Pre-Distribution Tax Period shall be prepared and filed by the Party (or Party’s Affiliate) that recorded the sale or purchase or qualifying use that gave rise to the Sales or Use Tax.

More Definitions of Pre-Distribution Tax Period

Pre-Distribution Tax Period means (i) any tax period beginning and ending before or on the Distribution Date and (ii) with respect to a period that begins before and ends after the Distribution Date, such portion of the tax period ending on and including the Distribution Date.

Pre-Distribution Tax Period means (i) any tax period beginning and ending before or on the Distribution Date and (ii) with respect to a period that begins on or before and ends after the Distribution Date, such portion of the tax period ending on and including the Distribution Date.

Pre-Distribution Tax Period means any taxable period (or portion thereof) that ends on or before the Distribution Date. “Prime Rate” means the “prime rate” as published in The Wall Street Journal, Eastern Edition.

Pre-Distribution Tax Period means any Tax Period (or portion thereof) ending on or before the close of the Distribution Date. “Privileged Documentation” has the meaning set forth in Section 8.03.

Pre-Distribution Tax Period means a Tax year beginning and ending on or before the Distribution Date. (105) “Pre-Distribution U.S. Income Tax Audit” means any Audit of any U.S. federal, state, or local Income Tax Return filed, or allegedly required to be filed, for any Pre-Distribution Tax Period or Straddle Tax Period by a Party or its Affiliates; provided, further, that any Audit involving competent authority proceedings and that (a) includes an item related to or arising from an intercompany transfer pricing adjustment under Section 482 of the Code and the Treasury Regulations thereunder, or an analogous provision under U.S. state or local or non -U.S. Law, and (b) involves a Taxing Authority outside of the United States, shall be treated as a Pre-Distribution U.S. Income Tax Audit for purposes of such item solely for purposes of the determination as to whether to proceed to competent authority and for purposes of the related U.S. competent authority proceedings.

Pre-Distribution Tax Period means, with respect to a given entity, any taxable period (or portion thereof) for which a Tax Return is filed, if such period ends on or before the Distribution Date. By way of example, if the Distribution Date were to occur on July 31, 2006, then for federal Income Tax purposes the period from July 1, 2006 through July 31, 2006 would constitute a Pre-Distribution Tax Period with respect to the members of the HBI Group immediately after the Distribution Date, even though the taxable income of those corporations for such period is includable on the Xxxx Xxx Consolidated Group’s Tax Return for that Group’s taxable year ending June 30, 2007.

Pre-Distribution Tax Period means any taxable period (or portion thereof) that ends on or before the Distribution Date. “Records” has the meaning set forth in S ection 3.06.