Examples of TCI Affiliated Group in a sentence
In the case of any portion of the Unused TCI Affiliated Group NOL arising in a member of the Liberty Group which is subject to separate return limitation year, Section 382 or other restrictions arising prior to the Merger Date (a "Liberty XXXX XXX"), such Liberty XXXX XXX shall be available to reduce the Liberty Group's payment obligation only to the extent such Liberty XXXX XXX is actually utilized by the AT&T Affiliated Group.
If any TCI Affiliated Group NOL for which Liberty has been paid pursuant to this Section 3(d)(viii) expires unutilized (whether by reason of any separate return limitation year or Section 382 restriction or otherwise), Liberty shall repay AT&T the amount of the payment in respect of such expired TCI Affiliated Group NOL, plus interest at 6.5 percent, compounded annually, from the date of deconsolidation.
For each taxable year or portion thereof ending after the Effective Date that a Subgroup is part of the TCI Affiliated Group, the amounts referred to in Section D.1. shall be calculated by taking into account the utilization of such tax attributes as though the Subgroup actually filed returns as described in such Section without regard to the actual filings of the TCI Affiliated Group.
Each of TCIC, Liberty and Ventures and each other member of their respective Subgroups are members of an affiliated group of corporations of which TCI is the parent and which files consolidated federal income tax returns pursuant to Section 1501 of the Code (the "TCI Affiliated Group").
The Federal Tax Benefit of such Subgroup for each taxable year or part thereof shall be equal to (i) the Regular Tax Benefit of the Subgroup, if the TCI Affiliated Group is not liable for Alternative Minimum Tax during such taxable year or portion thereof and (ii) the Alternative Minimum Tax Benefit of the Subgroup, if the TCI Affiliated Group is liable for Alternative Minimum Tax during such taxable year or portion thereof.
At such time that a Corresponding Paid Loss expires and cannot be used by the TCI Affiliated Group in any taxable year or part thereof to reduce its consolidated federal income tax liability, the Subgroup that has an Unpaid Loss in its Benefit Tracking Account that is paired with such Corresponding Paid Loss shall remove such Unpaid Loss from its Benefit Tracking Account.
For each taxable year or part thereof ending after the Effective Date that a Subgroup is included in the TCI Affiliated Group, TCI shall compute (i) the Regular Tax Liability of the Subgroup for such taxable year or part thereof and (ii) if the TCI Affiliated Group is liable for Alternative Minimum Tax, the Alternative Minimum Tax Liability of the Subgroup for such taxable year or part thereof.
TCI shall continue to prepare and file all federal income Tax Returns (the "TCI Consolidated Returns") which are required to be filed by the TCI Affiliated Group for all periods and will pay all Taxes shown as due thereon.
TCI shall prepare and file or shall cause to be filed all foreign income or franchise Tax Returns which are required to be filed for all members of the TCI Affiliated Group and each member of the TCI Affiliated Group will pay all Taxes shown as due on any such Tax Return that is thus prepared and filed on its behalf.
This Agreement shall constitute a direct obligation of each First Tier LLC and each corporation that is a member of the TCI Affiliated Group, and shall be deemed to have been adopted and affirmed on behalf of any limited liability company or corporation that becomes a First Tier LLC or a member of the TCI Affiliated Group.