Common use of Protective Section 336(e) Election Clause in Contracts

Protective Section 336(e) Election. Prior to June 30, 2015, the Parties shall cooperate to determine whether the Parties will enter into a binding, written agreement to make an election under Code Section 336(e) with respect to the Distribution in accordance with Treasury Regulations Section 1.336-2(h) and (j) (and any applicable provisions under state and local law). In the event the Parties make an election under Code Section 336(e) (and any applicable provisions under state and local law), (i) the Parties shall cooperate in the timely completion and/or filings of such elections and any related filings or procedures; and (ii) ▇▇▇▇▇▇▇ International shall make an election under Treasury Regulations Section 1.1502-13(f)(5)(ii) with respect to the Distribution.