Transaction Treated as Extraordinary Item. In determining the apportionment of Tax Items between Pre-Distribution Periods and Post-Distribution Periods, any Tax Items relating to the Transactions shall be treated as an extraordinary item described in Treasury Regulation Section 1.1502-76(b)(2)(ii)(C) and shall be allocated to Pre-Distribution Periods, and any Taxes related to such items shall be treated under Treasury Regulation Section 1.1502-76(b)(2)(iv) as relating to such extraordinary item and shall be allocated to Pre-Distribution Periods.
Appears in 7 contracts
Samples: Tax Sharing Agreement (General Semiconductor Inc), Distribution Agreement (Pactiv Corp), Tax Sharing Agreement (Tenneco Packaging Inc)
Transaction Treated as Extraordinary Item. In determining the apportionment of Tax Items between Pre-Distribution Periods and Post-Post- Distribution Periods, any Tax Items relating to the Transactions shall be treated as an extraordinary item described in Treasury Regulation Section 1.1502-76(b)(2)(ii)(C) and shall be allocated to Pre-Distribution Periods, and any Taxes related to such items shall be treated under Treasury Regulation Section 1.1502-76(b)(2)(iv) as relating to such extraordinary item and shall be allocated to Pre-Distribution Periods. Section 4.
Appears in 4 contracts
Samples: Tax Sharing Agreement (Newport News Shipbuilding Inc), Tax Sharing Agreement (Newport News Shipbuilding Inc), Tax Sharing Agreement (New Tenneco Inc)
Transaction Treated as Extraordinary Item. In determining the ----------------------------------------- apportionment of Tax Items between Pre-Distribution Periods and Post-Post- Distribution Periods, any Tax Items Item relating to the Transactions shall be treated as an extraordinary item described in Treasury Regulation Section 1.1502-1.1502- 76(b)(2)(ii)(C) and shall be allocated to Pre-Distribution Periods, and any Taxes related to such items shall be treated under Treasury Regulation Section 1.1502-76(b)(2)(iv) as relating to such extraordinary item and shall be allocated to Pre-Distribution Periods.
Appears in 3 contracts
Samples: Tax Sharing Agreement (Varian Associates Inc /De/), Tax Sharing Agreement (Varian Inc), Tax Sharing Agreement (Varian Semiconductor Equipment Associates Inc)
Transaction Treated as Extraordinary Item. In determining the apportionment of Tax Items between Pre-Distribution Periods and Post-Distribution Periods, any Tax Items Item relating to the Transactions shall be treated as an extraordinary item described in Treasury Regulation Section 1.1502-76(b)(2)(ii)(C) and shall be allocated to Pre-Distribution Periods, and any Taxes related to any such items Tax Item (including Restructuring Taxes) shall be treated under Treasury Regulation Section 1.1502-76(b)(2)(iv) as relating to such extraordinary item and shall be allocated to Pre-Distribution Periods.
Appears in 1 contract
Samples: Sharing and Indemnification Agreement (Emerging Communications Inc)
Transaction Treated as Extraordinary Item. In determining the apportionment of Tax Items between Pre-Distribution Periods and Post-Distribution Periods, any Tax Items relating to the Transactions shall be treated as an extraordinary item described in Treasury Regulation Section 1.1502-76(b)(2)(ii)(C) and shall be allocated to Pre-Distribution Periods, and any Taxes related to such items shall be treated under Treasury Regulation Section 1.1502-1.1502- 76(b)(2)(iv) as relating to such extraordinary item and shall be allocated to Pre-Distribution Periods.
Appears in 1 contract
Transaction Treated as Extraordinary Item. In determining the apportionment of Tax Items between Pre-Distribution Periods and Post-Post- Distribution Periods, any Tax Items Item relating to the Transactions shall be treated as an extraordinary item described in Treasury Regulation Section 1.1502-76(b)(2)(ii)(C) and shall be allocated to Pre-Distribution Periods, and any Taxes related to any such items Tax Item (including Restructuring Taxes) shall be treated under Treasury Regulation Section 1.1502-76(b)(2)(iv) as relating to such extraordinary item and shall be allocated to Pre-Distribution Periods.
Appears in 1 contract
Samples: Sharing and Indemnification Agreement (Atlantic Tele Network Inc /De)
