Earnings and Profits Allocation. SEACOR will advise Spinco in writing of the decrease in SEACOR earnings and profits attributable to the Distribution under Section 312(h) of the Code on or before the first anniversary of the Distribution.
Earnings and Profits Allocation. Oil States will advise Civeo in writing of the amount of Oil States earnings and profits allocable to Civeo under Section 312(h) of the Code on or before the first anniversary of the Distribution.
Earnings and Profits Allocation. FNF will advise JAX in writing of the decrease in FNF earnings and profits attributable to the Distribution under Section 312(h) of the Code on or before the first anniversary of the Distribution.
Earnings and Profits Allocation. HERC Parent will advise RAC Parent in writing of the decrease in HERC Parent earnings and profits attributable to the Distribution under Section 312(h) of the Code on or before the first anniversary of the Distribution.
Earnings and Profits Allocation. Forest will advise Lone Pine in writing of the amount of Forest earnings and profits allocable to Lone Pine under Section 312(h) of the Code on or before the first anniversary of the Distribution.
Earnings and Profits Allocation. Forest will advise Spinco in writing of the decrease in Forest earnings and profits attributable to the Distribution under Section 312(h) of the Code on or before the first anniversary of the Distribution.
Earnings and Profits Allocation. Distributing will advise Controlled in writing of the decrease in Distributing earnings and profits attributable to the Distribution under Section 312(h) of the Code on or before the first anniversary of the Distribution.
Earnings and Profits Allocation. The parties understand that the ------------------------------- method of allocation of federal income tax liabilities used for the determination of earnings and profits for federal income tax purposes under governing law may differ from the methods prescribed herein for sharing of economic burdens of such taxes. To the extent permitted by governing law and not otherwise inconsistent with the best interests of LSB, LSB agrees to make an election or take any other action permitted under governing law which would cause such method of allocation to resemble as closely as practical the method of sharing the economic burdens of such tax hereunder.
Earnings and Profits Allocation. The parties understand that the method of allocation of Consolidated Income Tax Liabilities used for the determination of earnings and profits for federal Income Tax purposes under applicable laws may differ from the methods prescribed herein for sharing the economic burdens of such Taxes. To the extent permitted by applicable laws and not otherwise inconsistent with the best interests of AGC, AGC agrees to make any elections or take any other action which would cause such prescribed method of allocation to resemble as closely as practical the method of sharing the economic burdens of such Tax provided in this Agreement.
Earnings and Profits Allocation. The parties understand that the ------------------------------- method of allocation of federal income Tax liabilities used for the determination of earning and profits for federal income Tax purposes under governing law may differ from the methods prescribed herein for sharing of economic burdens of such Taxes. To the extent permitted by governing law and not otherwise inconsistent with the best interests of Trilogy, Trilogy agrees to make an election or take any other action permitted under governing law which would cause such method of allocation to resemble as closely as practical the method of sharing the economic burdens of such Tax hereunder.
