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.
Appears in 2 contracts
Sources: Tax Allocation Agreement (Ameriprise Financial Inc), Tax Allocation Agreement (Ameriprise Financial Inc)