Section 965 Amount definition
Section 965 Amount means all liabilities for unpaid Taxes of the Company that are attributable to amounts includible in the income of the Company as a result of Section 965 of the Code (or any similar provision of state or local Law), including any net Tax liability that is payable in a future taxable year as a result of an election under Section 965(h) of the Code (or any similar provision of state or local Law) that was made on or prior to the Closing Date.
Section 965 Amount means all liabilities for unpaid Taxes of any Group Company (determined as of the Closing Date and taking into account, for the avoidance of doubt, prior payments of the net Tax liability arising as a result of Section 965 of the Code) that are attributable to amounts includible in the income of such Group Company as a result of Section 965 of the Code (or any similar provision of state or local Law), including any net Tax liability that is payable in a future taxable year as a result of an election under Section 965(h) of the Code (or any similar provision of state or local Law) that was made on or prior to the Closing Date.