General Allocation Method. The members of the Group shall allocate the consolidated tax or consolidated refund in accordance with the procedures set forth below. The result of the following provisions shall be referred to as a positive allocation or a negative allocation, as the case may be. (a) The total consolidated tax liability, after all losses and credits allowed in arriving at the consolidated tax liability, shall be apportioned initially to each member in an amount equal to the ratio which that portion of the consolidated taxable income attributable to each member having positive separate company taxable income bears to the combined taxable income of those members having positive separate company taxable income. (b) If the consolidated tax liability apportioned to a member in paragraph (a) is less than the consolidated tax liability of such member computed on a separate return basis, such member shall pay the difference to Alliant Energy Corporation, in addition to the amount determined under paragraph (a); the member(s) having separate company taxable loss to whom tax reduction is attributable shall receive credit for such tax reduction and shall receive payment pursuant to such credit from Alliant Energy Corporation pursuant to the provisions of Section 4. (c) Alliant Energy Corporation shall not receive payment for any tax reduction allowed under paragraph (b) above. If Alliant Energy Corporation receives credit for a tax reduction pursuant to paragraph (b), then each member having positive taxable income shall be entitled to receive a portion of the tax reduction using the allocation method in paragraph (a) above. Members having a taxable loss shall not participate in the allocation of Alliant Energy Corporation's tax reduction.
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Sources: Tax Allocation Agreement (Alliant Energy Corp), Tax Allocation Agreement (Alliant Energy Corp)
General Allocation Method. The members of the Group shall allocate the consolidated tax or consolidated refund in accordance with the procedures set forth below. The result of the following provisions shall be referred to as a positive allocation or a negative allocation, as the case may be.
(a) The total consolidated tax liability, after all losses and credits allowed in arriving at the consolidated tax liability, shall be apportioned initially to each member in an amount equal to the ratio which that portion of the consolidated taxable income attributable to each member having positive separate company taxable income bears to the combined taxable income of those members having positive separate company taxable income.
(b) If the consolidated tax liability apportioned to a member in paragraph (a) is less than the consolidated tax liability of such member computed on a separate return basis, such member shall pay the difference to Alliant Interstate Energy Corporation, in addition to the amount determined under paragraph (a); the member(s) having separate company taxable loss (other than Interstate Energy Corporation) to whom such tax reduction is attributable shall receive credit for such tax reduction and shall receive payment pursuant to such credit from Alliant Interstate Energy Corporation pursuant to the provisions of Section 45.
(c) Alliant Interstate Energy Corporation shall not receive payment for any tax reduction allowed under paragraph (b) above. If Alliant Interstate Energy Corporation receives credit for a tax reduction pursuant to paragraph (b), then each member having positive taxable income shall be entitled to receive a portion of the tax reduction using the allocation method in paragraph (a) above. Members having a taxable loss shall not participate in the allocation of Alliant Interstate Energy Corporation's =s tax reduction.
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General Allocation Method. The members of the Group shall allocate the consolidated tax or consolidated refund in accordance with the procedures set forth below. The result of the following provisions shall be referred to as a positive allocation or a negative allocation, as the case may be.
(a) The total consolidated tax liability, after all losses and credits allowed in arriving at the consolidated tax liability, shall be apportioned initially to each member in an amount equal to the ratio which that portion of the consolidated taxable income attributable to each member having positive separate company taxable income bears to the combined taxable income of those members having positive separate company taxable income.
(b) If the consolidated tax liability apportioned to a member in paragraph (a) is less than the consolidated tax liability of such member computed on a separate return basis, such member shall pay the difference to Alliant Energy Corporation, in addition to the amount determined under paragraph (a); the member(s) having separate company taxable loss to whom tax reduction is attributable shall receive credit for such tax reduction and shall receive payment pursuant to such credit from Alliant Energy Corporation pursuant to the provisions of Section 4.
. (c) Alliant Energy Corporation shall not receive payment for any tax reduction allowed under paragraph (b) above. If Alliant Energy Corporation receives credit for a tax reduction pursuant to paragraph (b), then each member having positive taxable income shall be entitled to receive a portion of the tax reduction using the allocation method in paragraph (a) above. Members having a taxable loss shall not participate in the allocation of Alliant Energy Corporation's tax reduction.
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