Treatment of Payments. The Parties agree that any payment made between the Parties pursuant to this Agreement or any other Ancillary Agreement with respect to a Pre-Distribution Period or as a result of an event or action occurring in a Pre-Distribution Period shall be treated, to the extent permitted by law, for all Tax purposes as a nontaxable payment (i.e., a distribution or a capital contribution) made immediately prior to the Distribution.
Appears in 8 contracts
Samples: Tax Sharing Agreement (Parametric Sound Corp), Tax Sharing Agreement (LRAD Corp), Tax Sharing Agreement (Parametric Sound Corp)
Treatment of Payments. The Parties agree that any payment made between the Parties pursuant to this Agreement or any other the Ancillary Agreement with respect to a Pre-Distribution Period or as a result of an event or action occurring in a Pre-Distribution Period Agreements shall be treated, to the extent permitted by law, for all Tax purposes as a nontaxable payment (i.e., a distribution or a capital contribution) made immediately prior to the Distribution.
Appears in 2 contracts
Samples: Tax Separation Agreement (Spectrum Group International, Inc.), Tax Separation Agreement (A-Mark Precious Metals, Inc.)
Treatment of Payments. The Parties agree that any payment made between the Parties pursuant to this Agreement or any other Ancillary Agreement with respect to a Pre-Distribution Period or as a result of an event or action occurring in a Pre-Distribution Period shall be treated, to the extent permitted by law, for all Tax purposes as a nontaxable payment (i.e., a distribution or a capital contribution) made immediately prior to the Distribution as made pursuant to an obligation existing between the Parties as of the Distribution.
Appears in 2 contracts
Samples: Tax Sharing Agreement (Furiex Pharmaceuticals, Inc.), Tax Sharing Agreement (Furiex Pharmaceuticals, Inc.)
Treatment of Payments. The Parties agree that any payment made between the Parties pursuant to this Agreement or any other Ancillary Transaction Agreement with respect to a Pre-Distribution Period or as a result of an event or action occurring in a Pre-Distribution Period shall be treated, to the extent permitted by law, for all Tax purposes as a nontaxable payment (i.e., a distribution or a capital contribution) made immediately prior to the Distribution.
Appears in 2 contracts
Samples: Tax Sharing Agreement (Idearc Inc.), Tax Sharing Agreement (Idearc Inc.)
