Earnings and Profits. For purposes of determining the earnings and profits of each Group Member, the tax liability of the Group shall be allocated among the Group Members in accordance with Treasury Regulation Sections 1.1552-1(a)(1) and 1.1502-33(d)(3).
Appears in 3 contracts
Samples: Allocation Agreement (National Grid Group PLC), Allocation Agreement (National Grid Group PLC), Allocation Agreement (National Grid Group PLC)
Earnings and Profits. For purposes of determining the earnings and profits of each Group Member, the tax liability of the Group shall be allocated among the Group Members in accordance with Treasury Regulation Sections 1.1552-1(a)(11(a)(2) and 1.1502-33(d)(3).
Appears in 2 contracts
Samples: Tax Allocation Agreement (Pepco Holdings Inc), Tax Allocation Agreement (New Rc Inc)
Earnings and Profits. For purposes of determining the earnings and profits of each member, the Group Member, shall elect to allocate the tax liability of the Group shall be allocated among the members of the Group Members in accordance with Treasury Regulation Sections the method prescribed in section 1552(a) (2) of the Code and section 1.1552-1(a)(11(a)(2) and 1.1502-33(d)(3)of the Regulations.
Appears in 2 contracts
Samples: Tax Allocation Agreement (Mbia Inc), Tax Allocation Agreement (Mbia Inc)
Earnings and Profits. For purposes of determining the earnings and profits of each member, the Group Member, shall elect to allocate the tax liability of the Group shall be allocated among the members of the Group Members in accordance with Treasury Regulation Sections the method prescribed in section 1552(a)(2) of the Code and sections 1.1552-1(a)(11(a)(2)(ii) and 1.1502-33(d)(3)) of the Regulations.
Appears in 1 contract
Samples: Tax Allocation Agreement (TIAA-CREF Life Insurance CO)
