US Tax Return means any return, declaration, report, or information return or statement filed with any US Taxation Authority, including any schedule or amendment thereto, and including any amendment thereof.
Each party hereto agrees to treat the Merger as a reorganization with the meaning of Section 368(a) of the Tax Code for all U.S. federal income tax purposes, and to not take any position on any U.S. Tax Return or otherwise take any U.S. Tax reporting position inconsistent with such treatment, unless otherwise required by applicable law.
After an employees US Tax Return has been filed, Ernst & Young LLP will prepare a tax reconciliation calculation.
Parent shall have filed all U.S. Tax Return and all State Tax Returns for income taxes required to be filed for the 2016 taxable year (regardless of when such Tax Returns are actually due), and shall have paid all such income taxes shown as due such Tax Returns.
Each Party agrees to not take any position on any U.S. Tax Return or otherwise take any Tax reporting position inconsistent with such treatment, unless otherwise required pursuant to a final determination by a Governmental Entity.
Broda currently is not the beneficiary of any extension of time within which to file any U.S. Tax Return.