Subgroups. There shall initially be four Subgroups, consisting of (1) BFC Financial Corporation and its Subsidiaries other than Woodbridge Holdings, LLC (“Woodbridge”) and Woodbridge’s Subsidiaries, and BBX Capital Corporation (“BBX”) and BBX’s Subsidiaries, (2) BBX and its Subsidiaries other than Woodbridge and Woodbridge’s Subsidaries, (3) Woodbridge and its Subsidiaries other than Bluegreen Corporation (“Bluegreen”) and Bluegreen’s subsidiaries, and (4) Bluegreen and its Subsidiaries. Any interest charges under IRC §453(l)(3) allocable to Bluegreen and its Subsidiaries shall be accounted for and paid by Bluegreen and its Subsidiaries. The allocation of tax items, liabilities and benefits shall be calculated within each Subgroup consistent with the provisions of this Agreement which are calculated for the Affiliated Group as a whole in a manner reasonably determined by the Parent.
Appears in 2 contracts
Sources: Agreement to Allocate Consolidated Income Tax Liabilities and Benefits (BFC Financial Corp), Agreement to Allocate Consolidated Income Tax Liabilities and Benefits (BBX Capital Corp)