Separate Tax Return Liability definition

Separate Tax Return Liability shall have the meaning set forth in Section 2.02(a)(iii).
View Source
Separate Tax Return Liability as applied to each member of the Pre-Deconsolidation Parent Group, means the amount of Tax such member would owe for any Pre-Deconsolidation Period, computed as if it had filed a separate Tax Return for each such period, adjusted as follows:
View Source
Separate Tax Return Liability of IWO or the remainder of the US Unwired Group, as the case may be, shall be computed as if such subgroup was a single member of the US Unwired Group with any separate return calculations computed as if the members of the subgroup filed a separate consolidated federal income tax return, and using the same elections and accounting methods as are used in determining the actual tax liability of the US Unwired Group.
View Source

Examples of Separate Tax Return Liability in a sentence

  • To the extent a TRS’ items of separate taxable income would be accorded a different tax treatment by operation of the consolidated return regulations, such TRS’ Separate Tax Return Liability shall be computed consistent with the consolidated return provisions to the extent such item resulted in an increase or decrease to the Group Tax Liability in the current or in a prior tax year.

  • Any AMT liability in excess of the sum of each TRS’ Separate Tax Return Liability for AMT shall be allocated to Liberty Mutual Insurance Company.

  • Any allocation of income or deductions required to determine any Consolidated Taxes (or Separate Tax Return Liability) attributable to any period beginning before and ending after the Effective Date shall be made by means of an interim closing of the books and records of IWO in accordance with, or utilizing principles consistent with, Treasury Regulation ss.

  • To the extent the Group Tax Liability is adjusted for any tax year as a result of an amended return, tax audit, administrative or judicial determination or re-determination or otherwise, the Separate Tax Return Liability for each TRS shall be recomputed to give effect to such adjustments.