Common use of Alternative Minimum Tax Clause in Contracts

Alternative Minimum Tax. (a) If the GP Affiliated Group has a consolidated federal alternative minimum tax ("AMT") liability for a Pre-Distribution Taxable Period, then (i) if the NPDC Group has Allocated Taxable Income for AMT purposes ("AMTI"), NPDC shall pay GP the federal AMT on the NPDC Group's AMTI for the taxable period; and (ii) if the NPDC Group has an Allocated Taxable Loss for AMT purposes ("AMTL") for the taxable period, GP shall pay NPDC the amount by which the GP Affiliated Group's federal AMT is reduced for the taxable period by reason of the NPDC Group's AMTL. (b) If the GP Affiliated Group has a net operating loss for consolidated federal AMT purposes ("AMT NOL") for a Pre-Distribution Taxable Period, then (i) if the GP Group and the NPDC Group both have AMTLs, the federal AMT refund or other Tax benefit arising from the AMT NOL shall be shared between the GP Group and the NPDC Group in proportion to their respective AMTLs for the taxable period; (ii) if the NPDC Group has an AMTL and the GP Group has AMTI, then GP shall pay NPDC the amount, if any, by which the GP Affiliated Group's federal AMT for the taxable period is reduced by reason of the NPDC Group's AMTL and the federal AMT refund or other Tax benefit arising from the AMT NOL shall be allocated to the NPDC Group; and (iii) if the NPDC Group has AMTI and the GP Group has an AMTL, then NPDC shall pay GP the amount, if any, by which the GP Affiliated Group's consolidated federal AMT for the taxable period is reduced by reason of the GP Group's AMTL and the federal AMT refund or other Tax benefit arising from the AMT NOL shall be allocated to the GP Group. (c) Any Tax benefit arising from the utilization of a consolidated federal AMT credit by the GP Affiliated Group will be allocated to the Group that paid (or was responsible under this Agreement for) the AMT that generated such AMT credit. The AMT credit will be treated as used on a "FIFO" basis. (d) The principles set forth in Sections 2.5(a) through 2.5(c) shall apply, mutatis mutandis, with respect to any Joint Return for a state, local or foreign jurisdiction that imposes an AMT, unless otherwise agreed with or mandated by a specific jurisdiction.

Alternative Minimum Tax. (ai) If the GP Hypothetical Common Stock/Wireless Affiliated Group has a consolidated federal alternative minimum tax ("AMT") AMT liability for a Pre-Distribution Taxable Periodsuch taxable period, then (iI) if the NPDC Wireless Group has Allocated Taxable Income for AMT purposes ("AMTI"), NPDC Wireless, as agent for the Wireless Group, shall pay GP AT&T the federal AMT on attributable to the NPDC Wireless Group's AMTI for the taxable period; period and (iiII) if the NPDC Wireless Group has an Allocated Taxable Loss for AMT purposes ("AMTL") ), AT&T shall pay Wireless, as agent for the taxable periodWireless Group, GP shall pay NPDC the amount by which the GP Hypothetical Common Stock/Wireless Affiliated Group's federal AMT is liability would be reduced for the taxable period by reason of the NPDC Wireless Group's AMTL. (bii) If the GP Hypothetical Common Stock/Wireless Affiliated Group has a net operating loss an NOL for consolidated federal AMT purposes ("AMT NOL") for a Pre-Distribution Taxable Periodsuch taxable period, then (iI) if the GP Common Stock Group and the NPDC Wireless Group both each have AMTLs, the federal AMT refund or other Tax benefit arising from the consolidated federal AMT NOL (and any payment from the Liberty Group in respect of Liberty Group alternative minimum taxable income with respect to such taxable period (a "Liberty AMT Sharing Payment")) shall be shared between the GP Common Stock Group and the NPDC Wireless Group in proportion to their respective AMTLs for the taxable period; , (iiII) if the NPDC Wireless Group has an AMTL and the GP Common Stock Group has AMTI, then GP AT&T shall pay NPDC Wireless, as agent for the Wireless Group, the amount, if any, by which the GP Affiliated Group's federal AMT for the taxable period is reduced by reason of the NPDC Group's AMTL and the federal AMT refund or other Tax benefit arising from the AMT NOL shall be allocated to the NPDC Group; and (iii) if the NPDC Group has AMTI and the GP Group has an AMTL, then NPDC shall pay GP the amount, if any, by which the GP Hypothetical Common Stock/Wireless Affiliated Group's consolidated federal AMT for the taxable period is reduced by reason of the GP Group's AMTL and the federal AMT refund or other Tax benefit arising from the AMT NOL shall be allocated to the GP Group.the (ciii) Any Tax benefit arising from a utilization by the utilization Hypothetical Common Stock/Wireless Affiliated Group of a consolidated federal AMT credit by the GP Affiliated Group will shall be allocated to the Group that which paid (or was responsible under this Agreement for) the AMT that generated such AMT credit. The AMT credit will be treated as used on a "FIFO" basis. (div) The principles set forth in Sections 2.5(asubparagraphs (i)-(iii) through 2.5(c) above shall apply, mutatis mutandis, with respect to any Joint Return for a state, local or foreign jurisdiction that imposes an AMT, unless otherwise agreed with or mandated by a specific jurisdiction.

Alternative Minimum Tax. (a) If the GP AT&T Affiliated Group has a consolidated federal alternative minimum tax ("AMT") liability for a Pre-Distribution Taxable Period, then (i) if the NPDC AT&T Broadband Group has Allocated Taxable Income for AMT purposes ("AMTI"), NPDC AT&T Broadband shall pay GP AT&T the federal AMT on the NPDC AT&T Broadband Group's AMTI for the taxable period; and (ii) if the NPDC AT&T Broadband Group has an Allocated Taxable Loss for AMT purposes ("AMTL") for the taxable period, GP AT&T shall pay NPDC AT&T Broadband the amount by which the GP AT&T Affiliated Group's federal AMT is reduced for the taxable period by reason of the NPDC AT&T Broadband Group's AMTL. (b) If the GP AT&T Affiliated Group has a net operating loss for consolidated federal AMT purposes ("AMT NOL") for a Pre-Distribution Taxable Period, then (i) if the GP AT&T Communications Group and the NPDC AT&T Broadband Group both have AMTLs, the federal AMT refund or other Tax benefit arising from the AMT NOL shall be shared between the GP AT&T Communications Group and the NPDC AT&T Broadband Group in proportion to their respective AMTLs for the taxable period; (ii) if the NPDC AT&T Broadband Group has an AMTL and the GP AT&T Communications Group has AMTI, then GP AT&T shall pay NPDC AT&T Broadband the amount, if any, by which the GP AT&T Affiliated Group's federal AMT for the taxable period is reduced by reason of the NPDC AT&T Broadband Group's AMTL and the federal AMT refund or other Tax benefit arising from the AMT NOL shall be allocated to the NPDC AT&T Broadband Group; and (iii) if the NPDC AT&T Broadband Group has AMTI and the GP AT&T Communications Group has an AMTL, then NPDC AT&T Broadband shall pay GP AT&T the amount, if any, by which the GP AT&T Affiliated Group's consolidated federal AMT for the taxable period is reduced by reason of the GP AT&T Communications Group's AMTL and the federal AMT refund or other Tax benefit arising from the AMT NOL shall be allocated to the GP AT&T Communications Group. (c) Any Tax benefit arising from the utilization of a consolidated federal AMT credit by the GP AT&T Affiliated Group will be allocated to the Group that paid (or was responsible under this Agreement for) the AMT that generated such AMT credit. The AMT credit will be treated as used on a "FIFO" basis. (d) The principles set forth in Sections 2.5(a3.5(a) through 2.5(c3.5(c) shall apply, mutatis mutandis, with respect to any Joint Return for a state, local or foreign jurisdiction that imposes an AMT, unless otherwise agreed with or mandated by a specific jurisdiction.