Consolidated Group Return definition

Consolidated Group Return means the U.S. federal income Tax Return of the Consolidated Group filed with respect to Taxes for any Taxable Year.
Consolidated Group Return means the consolidated Federal income tax return for a Consolidated Group. "Effective Date" means the date as set forth in Section 2.1 of this Agreement. "Final Determination" means the final resolution of liability for any Tax for any taxable period, including any related interest or penalties, by or as a result of: (i) a final and unappealable decision, judgment, decree or other order of a court of competent jurisdiction; (ii) a closing agreement or accepted offer in compromise under Sections 7121 or 7122 of the Code, or comparable agreement under the laws of other jurisdictions, which resolves the entire Tax liability for any Tax period; (iii) any allowance of a refund or credit in respect of an overpayment of Tax, but only after the expiration of all periods during which such refund may be recovered (including by way of offset) by the Tax imposing jurisdiction; or (iv) any other final disposition as determined by the Senior Tax Officer, including by reason of the expiration of the applicable statute of limitations. "IRS" means the United States Internal Revenue Service. "IRS Overpayment Rate" will have the meaning assigned to such term in Section 3.6 of this Agreement. "IRS Underpayment Rate" will have the meaning assigned to such term in Section 3.6 of this Agreement. "Member" means a corporation (including the common parent) which is included within a Consolidated Group. "Net Reversal Benefit" will have the meaning assigned to such term in Section 3.3(a) of this Agreement. "Realized Benefit" means a refund or reduction of tax liability resulting from the use of an item of loss, deduction or credit in accordance with the ordering rules prescribed by the Code and the regulations promulgated thereunder. "Records" means all data whether in written or electronic form including, but not limited to, invoices, journal entries, ledgers, supporting ledgers, schedules, financial statements including footnotes thereto used or relied upon to prepare Tax Returns or to substantiate tax basis in any asset owned by AFG or its Subsidiaries. "Senior Tax Officer" means such person who is appointed to the position of highest ranking tax officer of AFG.

Examples of Consolidated Group Return in a sentence

  • The benefit of any carryback of a Tax Item to any prior period Consolidated Return will be taken into account only when and to the extent that such carryback reduces the tax liability in a prior period Consolidated Group Return or that any resultant Net Reversal Benefit is realized.

  • In the event that any two or more Subsidiaries are not eligible to be included in THE HARTFORD Consolidated Group Return, but otherwise satisfy the requirements for inclusion in a Separate Consolidated Group, such Subsidiaries will join among themselves in the filing of a Separate Consolidated Group Return until consolidation with THE HARTFORD Group is permitted.

  • Odyssey Holdings, on behalf of the Subsidiaries, shall furnish Fairfax, at least sixty (60) days before the due date (including extensions) of any such Consolidated Group Return, with all information required by Fairfax to complete such Consolidated Group Return in accordance with instructions from Fairfax and in a manner consistent with prior returns, if any.

  • Interest determinations for Members will be made by the Director of Taxes at such time as the IRS finally determines interest owed for the tax year of the Consolidated Group Return.

  • Each of the Subsidiaries will join in the filing annually of THE HARTFORD Consolidated Group Return to the extent each is eligible to join in such return under the provisions of the Code and the regulations promulgated thereunder.

  • Semiconductor shall be responsible for, and shall pay on a timely basis and indemnify and hold C-Cube harmless on an After-Tax Basis from and against, all Pre-Semi Disposition Taxes and all Semi Spin Taxes, and to the extent such amounts are required to be reflected in any Consolidated Group Return, Combined Return and C-Cube Separate Company Return, such amounts shall be paid to C-Cube no later than three days prior to the time C-Cube is required to pay such Taxes without penalty or interest.

  • Notwithstanding the termination of this Agreement, any Member included in a Consolidated Group Return may inspect during regular business hours records of any other Member relating to such Consolidated Group Return, including, but not limited to, returns, supporting schedules, workpapers, correspondence and other documents.

  • The Subsidiaries that are members of the Consolidated Group or, if applicable, a Separate Consolidated Group, will execute and deliver all documentation reasonably required (including powers of attorney, if requested) to enable the Director of Taxes to file, and to take all actions necessary or incidental to the filing of, the Consolidated Group Return (including, without limitation, the execution of Treasury Form 1122) or any amendment of the Consolidated Group Return.

  • The Director of Taxes will cause to be timely prepared and filed all Tax Returns, including any Separate Consolidated Group Return, for all Subsidiaries of THE HARTFORD and will be responsible for the preparation and filing of any consents and requests for extension of time within which to file any such Tax Return or any related information.

  • Upon Owner's request, Contractor shall provide copies of all such plans, calculations, specifications and drawings to the aforementioned parties at no cost to Owner.