Reduction in Value of Foreign Tax Assets to Offset Loss of Federal Income Tax Deductions Sample Clauses

Reduction in Value of Foreign Tax Assets to Offset Loss of Federal Income Tax Deductions. The value, as otherwise determined under Section 4.2(c), of any Pre-IPO Tax Asset that reduces a Foreign Income Tax shall be reduced by the deemed lost Federal Income Tax related Tax Benefit, which shall be the product of (1) the value of such Pre-IPO Tax Asset as otherwise determined under Section 4.2(c) and (2) the highest statutory tax rate applicable under Section 11 of the Code.