Carryovers to Post-Affiliation Years Sample Clauses

Carryovers to Post-Affiliation Years. The Parties will apportion any U.S. federal consolidated net operating or capital losses, Credits or other applicable items between members of the SNI Group (departing from the EWS Group as a consequence of the Distribution and related transactions) and members of the EWS Group (not taking into account SNI Group members) pursuant to applicable Treasury Regulations promulgated under Section 1502 of the Code. Such consolidated items and their apportionment will be adjusted to reflect any Adjustments that take place in applicable Affiliation Years.
Sample 1Sample 2Sample 3
AutoNDA by SimpleDocs
Carryovers to Post-Affiliation Years. The Parties shall apportion any U.S. federal consolidated net operating or capital losses, Credits or other applicable items between members of the Scripps Spinco Group (departing from the Scripps Group as a consequence of the Distribution and related transactions) and members of the Scripps Group (not taking into account Scripps Spinco Group members) pursuant to applicable Treasury Regulations promulgated under Section 1502 of the Code. Such consolidated items and their apportionment shall be adjusted to reflect any Adjustments that take place with respect to applicable Affiliation Years.
Sample 1Sample 2
Carryovers to Post-Affiliation Years. The Parties shall apportion any U.S. federal consolidated net operating or capital losses, Credits or other applicable items between members of the Journal Spinco Group (departing from the Journal Group as a consequence of the Distribution and related transactions) and members of the Journal Group (not taking into account Journal Spinco Group members) pursuant to applicable Treasury Regulations promulgated under Section 1502 of the Code. Such consolidated items and their apportionment shall be adjusted to reflect any Adjustments that take place with respect to applicable Affiliation Years.
Sample 1Sample 2
Carryovers to Post-Affiliation Years. Section 7.2 Carrybacks from Post-Affiliation Years. 13 ARTICLE VIII U.S. FEDERAL INCOME TAX ADJUSTMENTS Section 8.1 Determination. Section 8.2 Payments. Section 8.3 Procedures. 14 Section 8.4 Intercompany Adjustments. 14 ARTICLE IX U.S. FEDERAL INCOME TAX PROCEEDINGS 15 Section 9.1 Lottery and Games Issues. 15 Section 9.2 Procedures. Section 9.3
Sample 1
Carryovers to Post-Affiliation Years. Games will apportion, in good faith, any U.S. federal consolidated net operating or capital losses, Credits or other applicable items between members of the Lottery Group (departing from the Games Group as a consequence of the Distribution and related transactions) and members of the Games Group (not taking into account Lottery members) pursuant to applicable Treasury Regulations promulgated under Section 1502 of the Code. Such consolidated items and their apportionment will be adjusted by Games to reflect any Adjustments that take place in applicable Affiliation Years.
Sample 1
Carryovers to Post-Affiliation Years. AXP will apportion, in good faith, any U.S. federal consolidated net operating or capital losses, Credits or other applicable items between members of the Ameriprise Group (departing from the AXP Group as a consequence of the Distribution and related transactions) and members of the AXP Group (not taking into account Ameriprise Group members) pursuant to applicable Treasury Regulations promulgated under Section 1502 of the Code. Such consolidated items and their apportionment will be adjusted by AXP to reflect any Adjustments that take place in applicable Affiliation Years.
Sample 1
Carryovers to Post-Affiliation Years. Wendy’s will apportion, in good faith, any U.S. federal consolidated net operating or capital losses, Credits or other applicable items between members of the Txx Hortons Group (departing from the Wendy’s Group as a consequence of the Distribution and related transactions) and members of the Wendy’s Group (not taking into account Txx Hortons Group members) pursuant to applicable Treasury Regulations promulgated under Section 1502 of the Code. Such consolidated items and 21 their apportionment will be adjusted by Wendy’s to reflect any Adjustments that take place in applicable Affiliation Years.
Sample 1
AutoNDA by SimpleDocs

Related to Carryovers to Post-Affiliation Years

  • Net Termination Gains and Losses After giving effect to the special allocations set forth in Section 6.1(d), all items of income, gain, loss and deduction taken into account in computing Net Termination Gain or Net Termination Loss for such taxable period shall be allocated in the same manner as such Net Termination Gain or Net Termination Loss is allocated hereunder. All allocations under this Section 6.1(c) shall be made after Capital Account balances have been adjusted by all other allocations provided under this Section 6.1 and after all distributions of Available Cash provided under Sections 6.4 and 6.5 have been made; provided, however, that solely for purposes of this Section 6.1(c), Capital Accounts shall not be adjusted for distributions made pursuant to Section 12.4.

  • Taxable Year The taxable year of the Partnership shall be the calendar year.

  • Limitation Year The Limitation Year is: (Choose (c) or (d)) [ x ] (c) The Plan Year. [ ] (d) The 12 consecutive month period ending every _____.

  • Gross Income Allocations In the event any Partner has a deficit balance in its Capital Account at the end of any Partnership taxable period in excess of the sum of (A) the amount such Partner is required to restore pursuant to the provisions of this Agreement and (B) the amount such Partner is deemed obligated to restore pursuant to Treasury Regulation Sections 1.704-2(g) and 1.704-2(i)(5), such Partner shall be specially allocated items of Partnership gross income and gain in the amount of such excess as quickly as possible; provided, that an allocation pursuant to this Section 6.1(d)(v) shall be made only if and to the extent that such Partner would have a deficit balance in its Capital Account as adjusted after all other allocations provided for in this Section 6.1 have been tentatively made as if this Section 6.1(d)(v) were not in this Agreement.

  • Gross Income Allocation If any Partner has a deficit Capital Account at the end of any Fiscal Year which is in excess of the sum of (i) the amount such Partner is obligated to restore, if any, pursuant to any provision of this Agreement, and (ii) the amount such Partner is deemed to be obligated to restore pursuant to the penultimate sentences of Treasury Regulations Section 1.704-2(g)(1) and 1.704-2(i)(5), each such Partner shall be specially allocated items of Partnership income and gain in the amount of such excess as quickly as possible; provided that an allocation pursuant to this Section 5.05(c) shall be made only if and to the extent that a Partner would have a deficit Capital Account in excess of such sum after all other allocations provided for in this Article V have been tentatively made as if Section 5.05(b) and this Section 5.05(c) were not in this Agreement.

  • Fiscal Year; Taxable Year The fiscal year and the taxable year of the Company is the calendar year.

  • Allocation of Net Income and Net Loss Net Income or Net Loss of the Partnership shall be determined as of the end of each calendar year and as of the end of any interim period extending through the day immediately preceding any (i) disproportionate Capital Contribution, (ii) disproportionate distribution, (iii) Transfer of a Partnership Interest in accordance with the terms of this Agreement, or (iv) Withdrawal Event. If a calendar year includes an interim period, the determination of Net Income or Net Loss for the period extending through the last day of the calendar year shall include only that period of less than twelve (12) months occurring from the day immediately following the last day of the latest interim period during the calendar year and extending through the last day of the calendar year. For all purposes, including income tax purposes, Net Income, if any, of the Partnership for each calendar year or interim period shall be allocated among the Partners in proportion to their respective Partnership Percentages for the calendar year or interim period. In the event of a Net Loss for a particular calendar year or interim period, then, for such calendar year or interim period, the Net Loss for such calendar year or interim period shall be allocated among the Partners in proportion to their respective Partnership Percentages for the calendar year or interim period.

  • Tax Year The Partnership’s tax year will end on , 20 .

  • Excess Contributions An excess contribution is any amount that is contributed to your IRA that exceeds the amount that you are eligible to contribute. If the excess is not corrected timely, an additional penalty tax of six percent will be imposed upon the excess amount. The procedure for correcting an excess is determined by the timeliness of the correction as identified below.

  • Vacation Year The vacation year shall be April 1 to March 31, inclusive.

Time is Money Join Law Insider Premium to draft better contracts faster.