Characterization. Any payment (other than interest thereon) made hereunder shall be treated by all parties for all purposes as a nontaxable intercompany settlement of liabilities existing immediately before the Distribution or, to the extent appropriate, as a non-taxable dividend distribution or capital contribution.
Appears in 18 contracts
Sources: Distribution Agreement (LTC Healthcare Inc), Distribution Agreement (LTC Properties Inc), Tax Sharing Agreement (LTC Properties Inc)