Allocation of Tax Items. In the case of a Deconsolidation Event, all tax computations for (i) any Pre-Deconsolidation Periods ending on the date of the Deconsolidation Event and (ii) the immediately following taxable period of Banpu Sub or any disaffiliated members of the Company Group, shall be made pursuant to the principles of Section 1.1502-76(b) of the Treasury Regulations or any similar provision of federal, state or local tax law, as agreed to by BNAC and Banpu Sub.
Appears in 3 contracts
Sources: Tax Sharing Agreement (BKV Corp), Tax Sharing Agreement (BKV Corp), Tax Sharing Agreement (BKV Corp)
Allocation of Tax Items. In the case of a Deconsolidation Event, all tax Tax computations with respect to applicable Combined Returns for (i) any Pre-Deconsolidation Periods ending on the date of the Deconsolidation Event and (ii) the immediately following taxable period of Banpu Sub Qualtrics or any disaffiliated members of the Company GroupQualtrics Affiliate, shall be made pursuant to the principles of Section 1.1502-76(b) of the Treasury Regulations or any similar of a corresponding provision under the laws of federal, state or local tax lawother jurisdictions, as agreed to reasonably determined by BNAC and Banpu SubSAP.
Appears in 3 contracts
Sources: Tax Sharing Agreement (Qualtrics International Inc.), Tax Sharing Agreement (Qualtrics International Inc.), Tax Sharing Agreement (Qualtrics International Inc.)
Allocation of Tax Items. In the case of a Deconsolidation Event, all tax Tax computations for (i1) any Pre-Deconsolidation Periods ending on the date of the Deconsolidation Event and (ii2) the immediately following taxable period of Banpu Sub Pivotal or any disaffiliated members of the Company GroupPivotal Affiliate, shall be made pursuant to the principles of Section 1.1502-76(b) of the Treasury Regulations or any similar of a corresponding provision under the laws of federal, state or local tax lawother jurisdictions, as agreed to reasonably determined by BNAC and Banpu SubDell Technologies, taking into account all reasonable suggestions made by Pivotal with respect thereto.
Appears in 2 contracts
Sources: Tax Sharing Agreement (Pivotal Software, Inc.), Tax Sharing Agreement (Pivotal Software, Inc.)
Allocation of Tax Items. In the case of a Deconsolidation Event, all tax Tax computations for (i) any Pre-Deconsolidation Periods ending on the date of the Deconsolidation Event and (ii) the immediately following taxable Taxable period of Banpu Sub the Company or any disaffiliated members of the Company Group, shall be made pursuant to the principles of Section 1.1502-76(b) of the Treasury Regulations or any similar provision of federal, state or local tax lawTax Law, as agreed to reasonably determined by BNAC and Banpu SubLMC.
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Allocation of Tax Items. In the case of a Deconsolidation Event, all tax Tax computations for (i) any Pre-Deconsolidation Periods ending on the date of the Deconsolidation Event and (ii) the immediately following taxable Taxable period of Banpu Sub the Company or any disaffiliated members of the Company Group, shall be made pursuant to the principles of Section 1.1502-76(b) of the Treasury Regulations or any similar provision of federal, state or local tax lawTax Law, as agreed to reasonably determined by BNAC and Banpu Sub.Embraer U.S.
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Allocation of Tax Items. In the case of a Deconsolidation Event, all tax Tax computations for (i1) any Pre-Deconsolidation Periods or portions thereof ending on the date of the Deconsolidation Event and (ii2) the immediately following taxable period of Banpu Sub Covisint or any disaffiliated members of the Company GroupCovisint Affiliate, shall be made pursuant to the principles of Section section 1.1502-76(b) of the Treasury Regulations or any similar of a corresponding provision under the laws of federal, state or local tax lawother jurisdictions, as agreed to reasonably determined by BNAC and Banpu SubCompuware, taking into account all reasonable suggestions made by Covisint with respect thereto.
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