Pre-Consolidation Tax Period means any tax period beginning before or on the date of Consolidation.
Pre-Distribution Tax Period means any taxable period (or portion thereof) that ends on or before the Distribution Date.
Post-Distribution Tax Period means a Tax period beginning and ending after the Distribution Date.
Tax Period means, with respect to any Tax, the period for which the Tax is reported as provided under the Code or other applicable Tax Law.
Straddle Tax Period means any taxable period beginning on or before and ending after the Closing Date.
Transaction Taxes has the meaning set forth in Section 6.01.
Distribution Taxes means any Taxes incurred solely as a result of the failure of the Intended Tax Treatment of the Restructuring, the Contribution or the Distribution.
Pre-Deconsolidation Period means any taxable period beginning on or prior to the applicable Deconsolidation Date.
Deconsolidation shall have the meaning provided in the Recitals.
Transaction Tax Deductions means any Tax deductions relating to (i) any pay down or satisfaction of Company Indebtedness or other Indebtedness, (ii) the payment or incurrence of any Transaction Expenses or Transaction Bonus Payments and (iii) any other deductible payments attributable to the Contemplated Transactions economically borne by the Seller. For this purpose, any success-based fees shall be treated as deductible in accordance with Rev. Proc. 2011-29.
Deconsolidation Date means the last date on which SpinCo qualifies as a member of the affiliated group (as defined in Section 1504 of the Code) of which Parent is the common parent.
Post-Closing Tax Period means any taxable period beginning after the Closing Date and, with respect to any Straddle Period, the portion of such Straddle Period beginning after the Closing Date.
Cumulative Consolidated Net Income means, for any period, Consolidated Net Income for such period, taken as a single accounting period. Cumulative Consolidated Net Income may be a positive or negative amount.
Non-Income Tax Return means any Tax Return relating to any Tax other than an Income Tax.
Income Tax Return means any return, declaration, report, claim for refund, or information return or statement relating to Income Taxes, including any schedule or attachment thereto, and including any amendment thereof.
Pre-Closing Tax Period means any Tax period ending on or before the Closing Date.
Pre-Closing Tax Periods means all taxable periods of the Company ending on or before the Closing Date.
Straddle Period means any Tax period beginning before or on and ending after the Closing Date.
Consolidated federal taxable income means the consolidated taxable income of an affiliated group of corporations, as computed for the purposes of filing a consolidated federal income tax return, before consideration of net operating losses or special deductions. "Consolidated federal taxable income" does not include income or loss of an incumbent local exchange carrier that is excluded from the affiliated group under division (A)(1) of this section.
Post-Deconsolidation Period means any taxable period beginning after the date of a Deconsolidation Event.
Pre-Closing Tax Return has the meaning set forth in Section 7.1(a).
Income Tax Expense means for Borrower and its Subsidiaries, on a consolidated basis for any period, all state and federal franchise or income taxes paid or due to be paid during such period.
Income Tax Returns mean all Tax Returns that relate to Income Taxes.
non-taxable territory means the territory which is outside the taxable territory;
Income Taxes means any taxes measured, in whole or in part, by net or gross income or profits together with any interest, penalties or additions to tax.
Post-Closing Straddle Period means the portion of a Straddle Period beginning the day after the Closing Date.