Common use of Reporting of Transactions Clause in Contracts

Reporting of Transactions. The Tax treatment of the Transactions reported on any Tax Return shall be consistent with the treatment thereof in the Ruling Requests and the Tax Opinions/Rulings. The Tax treatment reported on any Tax Return for which Corner Store is the Responsible Party shall be consistent with that on any Tax Return filed or to be filed by Valero or any member of the Valero Group or caused or to be caused to be filed by Valero, in each case with respect to periods prior to the Distribution Date or with respect to Straddle Periods (“Valero Group Transaction Returns”), to the extent Valero notifies Corner Store in writing of such Tax treatment. To the extent there is a Tax treatment relating to the Transactions which is not covered by the Ruling Requests, the Tax Opinions/Rulings or Valero Group Transaction Returns, the Tax treatment to be reported on any Tax Return shall be determined by Valero and the Responsible Company shall not take any position on any Tax Return that is inconsistent with such determination, provided that if (i) there is no reasonable basis, in the opinion of a Tax advisor from a nationally recognized legal, accounting or professional tax services firm, for the Tax treatment determined by Valero, or (ii) such Tax treatment is inconsistent with the Tax treatment contemplated in the Ruling Requests, the Tax Opinions/Rulings and/or the Valero Group Transaction Returns, then such Tax Return shall be submitted for review pursuant to Section 4.06(a), and any dispute regarding such proper Tax treatment shall be referred for resolution pursuant to Section 14, sufficiently in advance of the filing date of such Tax Return (including extensions) to permit timely filing of the Tax Return.

Appears in 3 contracts

Samples: Tax Matters Agreement (Corner Store Holdings, Inc.), Tax Matters Agreement (CST Brands, Inc.), Tax Matters Agreement (CST Brands, Inc.)

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Reporting of Transactions. The Tax treatment of the Transactions reported on any Tax Return shall be consistent with the treatment thereof in the Ruling Requests and the Tax Opinions/Rulings. The Tax treatment of the Transactions reported on any Tax Return for which Corner Store Enova is the Responsible Party Company shall be consistent with that on any Tax Return filed or to be filed by Valero Parent or any member of the Valero Parent Group or caused or to be caused to be filed by ValeroParent, in each case with respect to periods prior to the Distribution Date or with respect to Straddle Periods (“Valero Parent Group Transaction Returns”), to the extent Valero Parent notifies Corner Store Enova in writing of such Tax treatment. To the extent there is a Tax treatment relating to the Transactions which is not covered by the Ruling Requests, the Tax Opinions/Rulings or Valero Parent Group Transaction Returns, the Tax treatment to be reported on any Tax Return shall be determined by Valero Parent and the Responsible Company shall not take any position on any Tax Return that is inconsistent with such determination, provided that if (i) there is no reasonable basis, in the opinion of a Tax advisor from a nationally recognized legal, accounting or professional tax services firm, for the Tax treatment determined by ValeroParent, or (ii) such Tax treatment is inconsistent with the Tax treatment contemplated in the Ruling Requests, the Tax Opinions/Rulings and/or the Valero Parent Group Transaction Returns, then such Tax Return shall be submitted for review pursuant to Section 4.06(a4.06 (a), and any dispute regarding such proper Tax treatment shall be referred for resolution pursuant to Section 14, sufficiently in advance of the filing date of such Tax Return (including extensions) to permit timely filing of the Tax Return.

Appears in 2 contracts

Samples: Tax Matters Agreement (Enova International, Inc.), Tax Matters Agreement (Enova International, Inc.)

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