Certain Elections. Parent, in its sole discretion, shall be permitted to make a ratable election pursuant to Treasury Regulation 1.1502-76(b)(ii)(2) with respect to the distributive share of any SpinCo Entity that is treated as a partnership for U.S. federal income tax purposes.
Appears in 3 contracts
Sources: Tax Matters Agreement, Tax Matters Agreement (Cars.com Inc.), Tax Matters Agreement (Cars.com Inc.)