Common use of STATE TAX LIABILITIES Clause in Contracts

STATE TAX LIABILITIES. Any current state income tax liability or benefit associated with a state income tax return involving more than one subsidiary shall be allocated to such subsidiaries doing business in such state following the principles set forth herein for current federal income taxes, except that solely for purposes of allocating the New Hampshire business profits tax for any tax year ending on or before December 31, 1997, all of the New Hampshire business profits tax benefits available to a New Hampshire subsidiary (regardless of whether such benefits are used in the computation of the actual unitary tax liability of the group) shall be used in determining the allocation of such tax among the subsidiaries according to the following priority: (a) tax credits, (b) tax losses, and (c) other benefits, provided, however, that no New Hampshire subsidiary shall be reimbursed for any credit against the New Hampshire business profits tax used by another subsidiary until such time as the New Hampshire subsidiary that generated such tax credit could have utilized such credit to offfset its New Hampshire business profits tax liability and provided further that in no event shall the New Hampshire business profits tax liability allocated to any subsidiary exceed the separate return tax liability of such subsidiary. (See rule 45(c).

Appears in 2 contracts

Samples: Tax Allocation Agreement (Northeast Generation Co), Tax Allocation Agreement (Northeast Utilities System)

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STATE TAX LIABILITIES. (a) Generally and New Hampshire Business Profits Tax for Tax Years Ending on or Before December 31, 1997. Any current state income tax liability or benefit associated with a state income tax return involving more than one subsidiary shall be allocated to such subsidiaries doing business in such state following the principles set forth herein for current federal income taxes, except that solely for purposes of allocating the New Hampshire business profits tax for any tax year ending on or before December 31, 1997, all of the New Hampshire business profits tax benefits available to a New Hampshire subsidiary (regardless of whether such benefits are used in the computation of the actual unitary tax liability of the group) shall be used in determining the allocation of such tax among the subsidiaries according to the following priority: (a) tax credits, (b) tax losses, and (c) other benefits, provided, however, that no New Hampshire subsidiary shall be reimbursed for any credit against the New Hampshire business profits tax used by another subsidiary until such time as the New Hampshire subsidiary that generated such tax credit could have utilized such credit to offfset its New Hampshire business profits tax liability and provided further that in no event shall the New Hampshire business profits tax liability allocated to any subsidiary exceed the separate return tax liability of such subsidiary. (See rule 45(c).

Appears in 2 contracts

Samples: Tax Allocation Agreement (Northeast Utilities), Tax Allocation Agreement (Northeast Utilities System)

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