Protective Section 336(e) Election. (a) DTE will make a Protective Section 336(e) Election with respect to each of the Distributions. Accordingly, the Parties agree that this Agreement constitutes a written, binding agreement to make a Protective Section 336(e) Election with respect to each of the Distributions as contemplated by Section 1.336-2(h)(1)(i) of the Regulations. Spinco will cooperate with DTE to facilitate the making of such election.
Appears in 3 contracts
Sources: Tax Matters Agreement (Dte Energy Co), Tax Matters Agreement (DT Midstream, Inc.), Tax Matters Agreement (DT Midstream, Inc.)