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

Protective Section 336(e) Elections. (a) Ensign and SpinCo shall make a protective election with respect to SpinCo under Section 336(e) of the Code (and any similar election under state or local Law) 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) and shall fully cooperate in the timely completion and/or filings of such elections and any related filings or procedures (including filing or amending any Tax Returns to implement an election that becomes effective). This Section 2.07(a) is intended to constitute a binding, written agreement to make an election under Section 336(e) of the Code with respect to the Distribution.

Appears in 3 contracts

Samples: Tax Matters Agreement (Pennant Group, Inc.), Tax Matters Agreement (Ensign Group, Inc), Tax Matters Agreement (Pennant Group, Inc.)

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Protective Section 336(e) Elections. (a) Ensign RemainCo and SpinCo shall make a protective election with respect to SpinCo under Section 336(e) of the Code (and any similar election under state or local Lawlaw) with respect to the External Distribution in accordance with Treasury Regulations Section 1.336-2(h) and (j) (and any applicable provisions under state and local Lawlaw) and shall fully cooperate in the timely completion and/or filings of such elections and any related filings or procedures (including filing or amending any Tax Returns to implement an election that becomes effective). This Section 2.07(a5.6(a) is intended to constitute a binding, written agreement to make an election under Section 336(e) of the Code with respect to the External Distribution.

Appears in 2 contracts

Samples: Tax Matters Agreement (Wyndham Hotels & Resorts, Inc.), Tax Matters Agreement (Wyndham Hotels & Resorts, Inc.)

Protective Section 336(e) Elections. (a) Ensign Notwithstanding anything to the contrary, GB and SpinCo Nuvectra shall make a protective election with respect to SpinCo under Section 336(e) of the Code (and any similar election under state or local Lawlaw) 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) law), and shall fully cooperate in the timely completion and/or filings of such elections and any related filings or procedures (including filing or amending any Tax Returns to implement an a protective election that becomes effective). This Section 2.07(a) 3.4 is intended to constitute a binding, written agreement to make an election under Section 336(e) of the Code with respect to the DistributionSpin-off.

Appears in 1 contract

Samples: Tax Matters Agreement (Nuvectra Corp)

Protective Section 336(e) Elections. (a) Ensign Exelon and SpinCo Constellation shall make a protective election with respect to SpinCo Constellation under Section 336(e) of the Code (and any similar election under state or local Law) 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) and shall fully cooperate in the timely completion and/or filings of such elections and any related filings or procedures (including filing or amending any Tax Returns to implement an election that becomes effective). This Section 2.07(a2.08(a) is intended to constitute a binding, written agreement to make an election under Section 336(e) of the Code with respect to the Distribution.

Appears in 1 contract

Samples: Tax Matters Agreement (Exelon Corp)

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Protective Section 336(e) Elections. (a) Ensign Nxt-ID and SpinCo PartX shall make a protective election with respect to SpinCo PartX under Section 336(e) of the Code (and any similar election under state or local Lawlaw) 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 Lawlaw) and shall fully cooperate in the timely completion and/or filings of such elections and any related filings or procedures (including filing or amending any Tax Returns to implement an election that becomes effective). This Section 2.07(a3.05(a) is intended to constitute a binding, written agreement to make an election under Section 336(e) of the Code with respect to the Distribution.

Appears in 1 contract

Samples: Tax Matters Agreement (PartX, Inc.)

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