Timing Difference definition

Timing Difference means an increase in income, gain or recapture, or a decrease in deduction, loss or credit, as calculated for Income Tax purposes, of the taxpayer for any Post-Tax Indemnification Period coupled with an increase in deduction, loss or credit, or a decrease in income, gain or recapture, of the taxpayer for the Tax Indemnification Period.

Split View

AI-Powered Contracts

Draft, Review & Redline at the Speed of AI

Get StartedSchedule a Demo

Timing Difference means an adjustment to a Tax Return that results in (a) an increase in income, gain or recapture, or a decrease in deduction, loss or credit, of any Parent Entity for any Pre-Closing Tax Period and (b) an increase in deduction, loss or credit, or a decrease in income, gain or recapture, of any member of the SpinCo Group for a Post-Closing Tax Period.

Timing Difference means a decrease in income, gain or recapture, or an increase in deduction, loss or credit, as calculated for Income Tax purposes, of the taxpayer for any taxable period coupled with a decrease in deduction, loss or credit, or an increase in income, gain or recapture, of the taxpayer or a related taxpayer for the same or a subsequent taxable period.

Examples of Timing Difference in a sentence

• If any item of income, gain, recapture, loss, deduction, or credit of the GM Group is adjusted as part of a Final Determination for any tax year (whether or not this Agreement applies to that tax year), and the adjustment results in a Timing Difference, GM or Delphi, as appropriate, will pay to the party incurring the tax detriment an amount equal to the Tax Change.

• The party obtaining the Tax Change benefit will pay to the party incurring the Tax Change detriment the amount of the benefit, without interest, on the earlier of (i) the due date of the Income Tax Return on which the benefit is claimed (unless that return was filed before the Timing Difference arose), (ii) the date that a refund of the tax benefit is received, or (iii) the date that a taxing authority applies the tax benefit to an amount owed by the party receiving the tax benefit.

• However, each of the EOG 1995 Unsevered Adjustments shall be categorized as either a Timing Difference or a Permanent Difference.

• The failure to have taken such actions as shall have been legally available and necessary or appropriate to obtain the Income Tax Benefits resulting from such Reverse Timing Difference shall not relieve Networks from the obligation to make the payments that would have been due from Networks under Section 9.b had Networks (or the appropriate members of the Networks Group) taken such actions.

• A Timing Difference is any adjustment, whether by amended return or examination by a taxing authority, to any Tax Return that will reverse in a prior or subsequent Tax Return.

More Definitions of Timing Difference

Timing Difference means an increase in income, gain or recapture, or a decrease in deduction, loss or credit, as calculated for Income Tax purposes, of the taxpayer for any Post-Tax Indemnification Period coupled with an increase in deduction, loss or credit, or a decrease in income, gain or recapture, of the taxpayer for the Tax Indemnification Period. "Transfer Taxes" means all transfer, documentary, sales, use, registration, value-added and other similar Taxes (including all applicable real estate transfer Taxes and real property transfer gains Taxes) and related amounts (including any penalties, interest and additions to Tax) arising as a result of or otherwise incurred in connection with any of the transactions contemplated by the Merger Agreement or the Ancillary Agreements.

Timing Difference means an adjustment to the taxable income or credits of the GM Group which results in (i) an increase or decrease in the income, gain, recapture, deduction, loss or credit of either the GM Group or the Delphi Group for a particular tax year, and (ii) an offsetting increase or decrease in deduction, loss, credit, income, gain or recapture of the other party for other tax years. Timing Difference also means an adjustment to the taxable income of the Delphi Group and an offsetting adjustment to the taxable income of the GM Group for the same tax year.

Timing Difference means, unless otherwise indicated or where the context otherwise requires, the difference between the amount of debt portfolio purchases reported for a period and the amount of cash payments made in relation to debt portfolio purchases in such period;

Timing Difference means an adjustment to an Income Tax Return which results in (x) an increase in income, gain or recapture, or a decrease in deduction, loss or credit, as calculated for Income Tax purposes, of any member of the ▇▇▇▇▇▇ Post-Merger Group for any Post-Distribution Taxable Period or the portion of a Straddle Period beginning on the day after the Distribution Date and (y) an increase in deduction, loss or credit, or a decrease in income, gain or recapture, of a member of the GM Consolidated Group for a Pre-Distribution Taxable Period or the portion of a Straddle Period ending on the Distribution Date.

Timing Difference as defined in Section 11.4.2.2.

Timing Difference is defined in Section 5.2.

Timing Difference means, with respect to any item of income, loss, deduction or credit, an adjustment of any such item in a tax period which will result in an actual or potential corresponding adjustment in one or more other tax periods.