Common use of Tax Consequences of Payments Clause in Contracts

Tax Consequences of Payments. For all Tax purposes and to the extent permitted by applicable Tax Law, the parties hereto shall treat any payment made pursuant to this Agreement as a capital contribution or a distribution, as the case may be, immediately prior to the Distribution.

Tax Consequences of Payments. For all Tax purposes and to the extent permitted by applicable Tax Law, the parties hereto shall treat any payment (except as provided in Section 4.3) made pursuant to this Agreement as a capital contribution or a distribution, as the case may be, immediately prior to the DistributionDistribution or as payments of an assumed or retained liability.

Tax Consequences of Payments. For all Tax purposes and to the extent permitted by applicable Tax Lawlaw, the parties Parties hereto shall treat any payment made pursuant to this Agreement as a capital contribution by the relevant member or a distribution by the relevant member (or as adjustments to such contribution or distribution) (or as a distribution followed by a contribution) occurring immediately before the Effective Date. Consistent with the foregoing, payments made between BWHI and FHI shall be treated, to the extent permitted by applicable Tax law, as the case may be, immediately prior adjustments to the Distributionamount of the Contribution.

Tax Consequences of Payments. For all Tax purposes and to the extent permitted by applicable Tax Law, the parties hereto shall treat any payment made pursuant to this Agreement between the parties as a capital contribution or a distribution, as the case may be, immediately prior to the Distribution. For the avoidance of doubt, for all Tax purposes and to the extent permitted by applicable Tax Law, the Estimated 2046 Exchangeables Tax Benefits Amount related to any Splitco Indemnity Payment shall be treated as a reduction of the applicable Splitco Indemnity Payment under the Indemnification Agreement.

Tax Consequences of Payments. (a) For all Tax tax purposes and notwithstanding any other provision of this Agreement, to the extent permitted by applicable Tax Lawlaw, the parties hereto shall treat any payment made pursuant to this Agreement (other than an interest payment) as a capital contribution or a dividend distribution, as the case may be, immediately prior to the DistributionDistribution Date and, accordingly, as not includible in the taxable income of the recipient.

Tax Consequences of Payments. For all Tax purposes and to the extent permitted by applicable Tax Lawlaw, the parties hereto shall treat any payment made pursuant to this Agreement as a capital contribution or a distribution, as the case may be, immediately prior to the DistributionEffective Date and, accordingly, as not includible in the taxable income of the recipient.

Tax Consequences of Payments. For all Tax purposes and to the extent permitted by applicable Tax Law, the parties hereto shall treat any payment made pursuant to this Agreement as a capital contribution or a distribution, as the case may be; provided, immediately prior that such payment does not relate to a Tax allocated to the Distributionpayor in accordance with Section 1552 of the Code or the regulations thereunder or Treasury Regulations Section 1.1502-33(d) (or under corresponding principles of other applicable Tax Laws)).

Tax Consequences of Payments. For all Tax purposes and ------------------------------ to the extent permitted by applicable Tax Lawlaw, the parties hereto shall treat any payment made pursuant to this Agreement as a capital contribution or a dividend distribution, as the case may be, immediately prior to the DistributionEffective Date and, accordingly, as not includible in the taxable income of the recipient.

Tax Consequences of Payments. For all Tax purposes and to the extent permitted by applicable Tax Lawlaw, the parties hereto shall treat any payment made pursuant to this Agreement as a capital contribution or a dividend distribution, as the case may be, immediately prior to the DistributionEffective Date and, accordingly, as not includible in the taxable income of the recipient.

Tax Consequences of Payments. For all Tax purposes and to the extent permitted by applicable Tax Law, the parties hereto shall treat any payment made pursuant to this Agreement between the parties as a capital contribution or a distribution, as the case may be, immediately prior to the Distribution.