Pre-Deconsolidation Period definition
Examples of Pre-Deconsolidation Period in a sentence
In the event of a carry-forward or carry-back of tax credits, each member’s respective tax credits shall be taken into account for purposes of this allocation in the Pre-Deconsolidation Period, if any, in which such tax credits are used to reduce, and to the extent they reduce, the consolidated, combined or unitary State Income Tax of the Pre-Deconsolidation Parent Group.
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 ▇▇▇▇ 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.
If WhiteWave is required by law to carry back any such Tax Asset to a Pre-Deconsolidation Period, ▇▇▇▇ 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 ▇▇▇▇ Foods or ▇▇▇▇ Foods Affiliates.
SpinCo hereby agrees that Distributing shall be entitled to determine in its sole discretion whether (x) any Adjustment Request with respect to any Joint Return shall be filed to claim in any Pre-Deconsolidation Period any SpinCo Carried Item, and (y) any available elections shall be made to waive the right to claim in any Pre-Deconsolidation Period with respect to any Joint Return any SpinCo Carried Item, and whether any affirmative election shall be made to claim any such SpinCo Carried Item.