Common use of Allocation of Consolidated Tax Liability Clause in Contracts

Allocation of Consolidated Tax Liability. With respect to the determination of earnings and profits for federal income tax purposes, the Consolidated Tax Liability for each taxable year shall be allocated among the Members in accordance with the methods prescribed in Treas. Reg. (section)1.1552-1(a)(2) and Treas. Reg. (section)1.1502-33(d)(2)(ii) commencing with the tax year ending February 3, 1996. The fixed percentage to be used for purposes of Treas. Reg. (section)1.1502-33(d)(2)(ii)(b) is 100 percent.

Allocation of Consolidated Tax Liability. With respect to the determination of earnings and profits for federal income tax purposes, the Consolidated Tax Liability for each taxable year shall be allocated among the Members in accordance with the methods prescribed in Treas. Reg. (section)1.1552Section 1.1552-1(a)(2) and Treas. Reg. (section)1.1502Section 1.1502-33(d)(2)(ii) commencing with the tax year ending February 3December 31, 19961999. The fixed percentage to be used for purposes of Treas. Reg. (section)1.1502Section 1.1502-33(d)(2)(ii)(b) is 100 percent.