Tax Attribute definition

Tax Attribute means a net operating loss, net capital loss, unused investment credit, unused foreign tax credit, excess charitable contribution, general business credit or any other Tax Item that could reduce a Tax.

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Tax Attribute means net operating losses, capital losses, research and experimentation credit carryovers, investment tax credit carryovers, earnings and profits, foreign tax credit carryovers, overall foreign losses, overall domestic losses, previously taxed earnings and profits, separate limitation losses and any other losses, deductions, credits or other comparable items that could affect a Tax Liability for a past, current or future Tax Period, other than the basis or adjusted basis of any property or any depreciation, amortization or other deductions or offsets attributable thereto.

Tax Attribute means a Tax Item of a member of the Partnership Group reflected on a Combined Return that is comparable to one or more of the following attributes with respect to a U.S. federal income tax consolidated tax return: a net operating loss, a net capital loss, an unused investment credit, an unused foreign tax credit, an excess charitable contribution, a U.S. federal minimum tax credit or a U.S. federal general business credit (but not tax basis or earnings and profits).

Examples of Tax Attribute in a sentence

• Any dispute regarding the allocation or apportionment of such earnings and profits or any Tax Attribute shall be resolved pursuant to the provisions of Section 14 of this Agreement.

• The Parties agree that (i) Medtronic is not providing a representation, warrantee or guarantee regarding the amount of any Tax Attribute pursuant to this Section 3.9 and (ii) Medtronic shall not be liable to any member of the SplitCo Group for any failure of any determination under this Section 3.9 to be accurate under applicable Law.

• SplitCo shall not take any action inconsistent with the assumptions made (including with respect to any Tax Attribute or other Tax Item) in determining all estimated or advance payments of Taxes on or prior to the Divestment Date.

• Parent shall in good faith advise Spinco in writing of the portion of any and all earnings and profits and Tax Attribute, or other consolidated, combined or unitary attribute which Parent has so allocated or apportioned to Spinco in accordance with applicable Tax Law.

More Definitions of Tax Attribute

Tax Attribute means a net operating loss, net capital loss, unused investment credit, unused foreign Tax credit, excess charitable contribution, general business credit, research and development credit, earnings and profits, basis, or any other Tax item that could reduce a Tax or create a refund, credit, or other item that causes reduction in an otherwise required liability for Taxes.

Tax Attribute means a net operating loss, net capital loss, unused investment credit, unused foreign Tax credit, excess charitable contribution, general business credit, research and development credit, earnings and profits, basis, or any other Tax Item that could reduce a Tax or create a Tax Benefit.

Tax Attribute means a consolidated, combined or unitary net operating loss, net capital loss, unused investment credit, unused foreign tax credit, or excess charitable contribution (as such terms are used in Treasury Regulations 1.1502-79 and 1.1502-79A or comparable provisions of foreign, state or local tax law), or a minimum tax credit or general business credit.

Tax Attribute or “Attribute” means a net operating loss, net capital loss, unused investment credit, unused foreign tax credit, excess charitable contribution, general business credit, Tax basis or any other Tax Item that could reduce a Tax.

Tax Attribute has the meaning set forth in Section 2.04.

Tax Attribute means any Tax attribute, including any net operating loss, net capital loss or Tax credit.

Tax Attribute means any item of basis of property, any item of loss (including a net operating loss carryover), any item of credit and any other Tax item that would otherwise be taken into account in a Tax period ending after the Closing Date.