Adjusting Payments. For any Consolidated Tax Period, if any item of income, gain, loss, deduction or credit of the GM Group is adjusted by the IRS or by a state or locality and such change is part of a Final Determination, then GM will pay Hughes or Hughes will pay GM an amount, including any interest paid ▇▇ ▇▇▇eive▇ ▇▇ ▇he GM Group and any penalties or additions to tax imposed on the GM Group, as may be necessary to adjust the payments between Hughes and GM to reflect payments that would have been made under th▇▇ ▇▇▇eement or the 1985 TAA or, with respect to items relating to payments made on Consolidated State or Local Income Tax Returns for tax years 1985 through 1997, in accordance with the past custom and practice of the parties, had the adjustment as finally determined been taken into account in determining the amount of those payments.
Appears in 1 contract
Sources: Agreement for the Allocation of United States Income Taxes (Hec Holdings Inc)
Adjusting Payments. For any Consolidated Tax Period, if any item of income, gain, loss, deduction or credit of the GM Group is adjusted by the IRS or by a state or locality and such change is part of a Final Determination, then GM will pay Hughes or Hughes will pay GM an amount, including any interest paid o▇ ▇▇▇▇ived ▇▇ ▇▇▇eive▇ ▇▇ ▇he e GM Group and any penalties or additions to tax imposed on the GM Group, as may be necessary to adjust the payments between Hughes and GM to reflect payments that would have been made under th▇thi▇ ▇▇▇eement ▇ement or the 1985 TAA or, with respect to items relating to payments made on Consolidated State or Local Income Tax Returns for tax years 1985 through 1997, in accordance with the past custom and practice of the parties, had the adjustment as finally determined been taken into account in determining the amount of those payments.
Appears in 1 contract
Sources: Agreement for the Allocation of United States Income Taxes (News Corp LTD)