Pre-Deconsolidation Period definition

Pre-Deconsolidation Period means any Tax Period ending on or before the Deconsolidation Date, and, in the case of any Straddle Period, the portion of such Straddle Period ending on the Deconsolidation Date.
Pre-Deconsolidation Period means any taxable period beginning on or prior to the applicable Deconsolidation Date.
Pre-Deconsolidation Period means any period ending on or before the Deconsolidation Date.

Examples of Pre-Deconsolidation Period in a sentence

  • If WhiteWave is required by law to carry back any such Tax Asset to a Pre-Deconsolidation Period, Xxxx Foods agrees to make a payment to WhiteWave to the extent that such a payment would otherwise be required under the terms of Section 3.5(d) or Section 3.6(b) of this Agreement, net of any expenses incurred by Xxxx Foods or Xxxx Foods Affiliates.

  • All computations with respect to any Pre-Deconsolidation Period shall be made pursuant to the principles of Treasury Regulations Section 1.1502-76(b), taking into account such elections thereunder as Xxxx Foods, in its sole discretion, shall make.

  • In the event any Tax Asset of the WhiteWave Group for any Post-Deconsolidation Period is eligible to be carried back to a Pre-Deconsolidation Period, WhiteWave shall, to the extent permitted by applicable law, elect to carry such amounts forward to any Post-Deconsolidation Period.

  • In the case of a Deconsolidation Event, Dell Technologies agrees to pay to VMware the Tax Benefit from the use in any Pre-Deconsolidation Period of a carryback of any Tax Asset of the VMware Group from a Post-Deconsolidation Period (other than a carryback of any Tax Asset attributable to Distribution Taxes for which the liability is borne by Dell Technologies or any Dell Technologies Affiliate).

  • If the amount of the KBR Allocated Attributes for the Pre-Deconsolidation Period is greater than the amount of the KBR Stand-Alone Attributes, the value of such excess, to the extent such excess is attributable to the use of Tax Attributes of ESG Group Members by KBR Group Members during such period, shall be paid by KBR to Halliburton within thirty (30) days of the date the KBR Allocated Attributes are determined.


More Definitions of Pre-Deconsolidation Period

Pre-Deconsolidation Period means any taxable period (or portion thereof) ending on or before the close of business on the Deconsolidation Date.
Pre-Deconsolidation Period shall have the meaning set forth in the Tax Matters Agreement.
Pre-Deconsolidation Period means any taxable period with respect to a Reuters Consolidated Return, Reuters Combined Return, or Instinet Combined Return as the case may be, beginning on or before the close of business on the applicable Deconsolidation Date.
Pre-Deconsolidation Period means any taxable period beginning on or before the date of a
Pre-Deconsolidation Period means any period ending on or before the Deconsolidation Date. “Required Tax Attribute Carryback” is defined in Section 5.08 hereof.
Pre-Deconsolidation Period means any period ending on or before the Deconsolidation Date. “Preliminary Distributions” is defined in the Recitals to this Agreement.
Pre-Deconsolidation Period means any taxable period with respect to -------------------------- a Consolidated Return or Combined Return, as the case may be, (i) beginning with respect to Subsidiary and/or any Subsidiary Affiliate on or after the Separation Date and on or before a Deconsolidation Date, and/or (ii) the portion of the Straddle Period ending on the Deconsolidation Date. "Pre-Restructuring Foreign Dividend" means (i) the payment of an ---------------------------------- actual dividend (as defined under U.S. Tax law) by a foreign Subsidiary Affiliate to Subsidiary or Parent; (ii) a transaction which by its terms will give rise to a deemed dividend under Section 956 of the Code; (iii) a transaction by which a foreign Subsidiary Affiliate makes a distribution which is treated as a return of capital (due to the absence of accumulated earnings and profits for U.S. Tax purposes); or (iv) a transaction by which a foreign Subsidiary Affiliate makes a distribution which for U.S. purposes is treated as a distribution of previously taxed income (as defined in Section 959 of the Code), in each case prior to or in connection with the Restructuring. "Privilege" means any privilege that may be asserted under applicable --------- law including any privilege arising under or relating to the attorney-client relationship (including the attorney-client and work product privileges), the accountant-client privilege, and any privilege relating to internal evaluation processes. "Prime Rate" means, for any day, the rate of interest per annum ---------- established from time to time by The Chase Manhattan Bank as its prime rate in effect on such day at its principal office in New York City, plus 150 basis points. "Pro Forma Subsidiary Group Combined Return" means a pro forma Non- ------------------------------------------ Federal Combined Tax return or other schedule prepared pursuant to Section 4.3 of this Agreement. "Pro Forma Subsidiary Group Consolidated Return" means a pro forma ---------------------------------------------- consolidated Federal Income Tax return or other schedule prepared pursuant to Section 4.2 of this Agreement. -7- <PAGE> "Proceeding" means any assessment, audit, or other examination by any ---------- Tax Authority, relating to Taxes (including Refunds), whether administrative or judicial, and any appeal of the foregoing. "Qualified Tax Counsel" means a nationally recognized independent --------------------- public accounting firm or law firm, which does not currently re...