Common use of Alternative Minimum Tax Clause in Contracts

Alternative Minimum Tax. (i) If the Hypothetical Common Stock/Wireless Affiliated Group has a consolidated federal AMT liability for such taxable period, then (I) if the Wireless Group has Allocated Taxable Income for AMT purposes ("AMTI"), Wireless, as agent for the Wireless Group, shall pay AT&T the AMT attributable to the Wireless Group's AMTI for the taxable period and (II) if the Wireless Group has an Allocated Taxable Loss for AMT purposes ("AMTL"), AT&T shall pay Wireless, as agent for the Wireless Group, the amount by which the Hypothetical Common Stock/Wireless Affiliated Group's AMT liability would be reduced for the taxable period by reason of the Wireless Group's AMTL. (ii) If the Hypothetical Common Stock/Wireless Affiliated Group has an NOL for consolidated federal AMT purposes ("AMT NOL") for such taxable period, then (I) if the Common Stock Group and the Wireless Group each have AMTLs, the federal AMT refund or other Tax benefit arising from the consolidated federal AMT NOL (and any payment from the Liberty Group in respect of Liberty Group alternative minimum taxable income with respect to such taxable period (a "Liberty AMT Sharing Payment")) shall be shared between the Common Stock Group and the Wireless Group in proportion to their respective AMTLs for the taxable period, (II) if the Wireless Group has an AMTL and the Common Stock Group has AMTI, then AT&T shall pay Wireless, as agent for the Wireless Group, the amount, if any, by which the Hypothetical Common Stock/Wireless Affiliated Group's consolidated federal AMT for the (iii) Any Tax benefit arising from a utilization by the Hypothetical Common Stock/Wireless Affiliated Group of a consolidated federal AMT credit shall be allocated to the Group which paid the AMT that generated such AMT credit. The AMT credit will be treated as used on a "FIFO" basis. (iv) The principles set forth in subparagraphs (i)-(iii) above shall apply, mutatis mutandis, with respect to any Joint Return for a state, local or foreign jurisdiction that imposes an AMT, unless otherwise agreed with or mandated by a specific jurisdiction.

Alternative Minimum Tax. (ia) If the Hypothetical Common Stock/Wireless GP Affiliated Group has a consolidated federal AMT alternative minimum tax ("AMT") liability for such taxable perioda Pre-Distribution Taxable Period, then (Ii) if the Wireless NPDC Group has Allocated Taxable Income for AMT purposes ("AMTI"), Wireless, as agent for the Wireless Group, NPDC shall pay AT&T GP the federal AMT attributable to on the Wireless NPDC Group's AMTI for the taxable period period; and (IIii) if the Wireless NPDC Group has an Allocated Taxable Loss for AMT purposes ("AMTL")) for the taxable period, AT&T GP shall pay Wireless, as agent for the Wireless Group, NPDC the amount by which the Hypothetical Common Stock/Wireless GP Affiliated Group's federal AMT liability would be is reduced for the taxable period by reason of the Wireless NPDC Group's AMTL. (iib) If the Hypothetical Common Stock/Wireless GP Affiliated Group has an NOL a net operating loss for consolidated federal AMT purposes ("AMT NOL") for such taxable perioda Pre-Distribution Taxable Period, then (Ii) if the Common Stock GP Group and the Wireless NPDC Group each both have AMTLs, the federal AMT refund or other Tax benefit arising from the consolidated federal AMT NOL (and any payment from the Liberty Group in respect of Liberty Group alternative minimum taxable income with respect to such taxable period (a "Liberty AMT Sharing Payment")) shall be shared between the Common Stock GP Group and the Wireless NPDC Group in proportion to their respective AMTLs for the taxable period, ; (IIii) if the Wireless NPDC Group has an AMTL and the Common Stock GP Group has AMTI, then AT&T GP shall pay Wireless, as agent for the Wireless Group, NPDC the amount, if any, by which the Hypothetical Common Stock/Wireless GP Affiliated Group's federal AMT for the taxable period is reduced by reason of the NPDC Group's AMTL and the federal AMT refund or other Tax benefit arising from the AMT NOL shall be allocated to the NPDC Group; and (iii) if the NPDC Group has AMTI and the GP Group has an AMTL, then NPDC shall pay GP the amount, if any, by which the GP Affiliated Group's consolidated federal AMT for thethe taxable period is reduced by reason of the GP Group's AMTL and the federal AMT refund or other Tax benefit arising from the AMT NOL shall be allocated to the GP Group. (iiic) Any Tax benefit arising from a the utilization by the Hypothetical Common Stock/Wireless Affiliated Group of a consolidated federal AMT credit shall by the GP Affiliated Group will be allocated to the Group which that paid (or was responsible under this Agreement for) the AMT that generated such AMT credit. The AMT credit will be treated as used on a "FIFO" basis. (ivd) The principles set forth in subparagraphs (i)-(iiiSections 2.5(a) above through 2.5(c) shall apply, mutatis mutandis, with respect to any Joint Return for a state, local or foreign jurisdiction that imposes an AMT, unless otherwise agreed with or mandated by a specific jurisdiction.

Alternative Minimum Tax. (ia) If the Hypothetical Common Stock/Wireless AT&T Affiliated Group has a consolidated federal AMT alternative minimum tax ("AMT") liability for such taxable perioda Pre-Distribution Taxable Period, then (Ii) if the Wireless AT&T Broadband Group has Allocated Taxable Income for AMT purposes ("AMTI"), Wireless, as agent for the Wireless Group, AT&T Broadband shall pay AT&T the federal AMT attributable to on the Wireless AT&T Broadband Group's AMTI for the taxable period period; and (IIii) if the Wireless AT&T Broadband Group has an Allocated Taxable Loss for AMT purposes ("AMTL")) for the taxable period, AT&T shall pay Wireless, as agent for the Wireless Group, AT&T Broadband the amount by which the Hypothetical Common Stock/Wireless AT&T Affiliated Group's federal AMT liability would be is reduced for the taxable period by reason of the Wireless AT&T Broadband Group's AMTL. (iib) If the Hypothetical Common Stock/Wireless AT&T Affiliated Group has an NOL a net operating loss for consolidated federal AMT purposes ("AMT NOL") for such taxable perioda Pre-Distribution Taxable Period, then (Ii) if the Common Stock AT&T Communications Group and the Wireless AT&T Broadband Group each both have AMTLs, the federal AMT refund or other Tax benefit arising from the consolidated federal AMT NOL (and any payment from the Liberty Group in respect of Liberty Group alternative minimum taxable income with respect to such taxable period (a "Liberty AMT Sharing Payment")) shall be shared between the Common Stock AT&T Communications Group and the Wireless AT&T Broadband Group in proportion to their respective AMTLs for the taxable period, ; (IIii) if the Wireless AT&T Broadband Group has an AMTL and the Common Stock AT&T Communications Group has AMTI, then AT&T shall pay Wireless, as agent for the Wireless Group, AT&T Broadband the amount, if any, by which the Hypothetical Common Stock/Wireless AT&T Affiliated Group's federal AMT for the taxable period is reduced by reason of the AT&T Broadband Group's AMTL and the federal AMT refund or other Tax benefit arising from the AMT NOL shall be allocated to the AT&T Broadband Group; and (iii) if the AT&T Broadband Group has AMTI and the AT&T Communications Group has an AMTL, then AT&T Broadband shall pay AT&T the amount, if any, by which the AT&T Affiliated Group's consolidated federal AMT for thethe taxable period is reduced by reason of the AT&T Communications Group's AMTL and the federal AMT refund or other Tax benefit arising from the AMT NOL shall be allocated to the AT&T Communications Group. (iiic) Any Tax benefit arising from a the utilization by the Hypothetical Common Stock/Wireless Affiliated Group of a consolidated federal AMT credit shall by the AT&T Affiliated Group will be allocated to the Group which that paid (or was responsible under this Agreement for) the AMT that generated such AMT credit. The AMT credit will be treated as used on a "FIFO" basis. (ivd) The principles set forth in subparagraphs (i)-(iiiSections 3.5(a) above through 3.5(c) shall apply, mutatis mutandis, with respect to any Joint Return for a state, local or foreign jurisdiction that imposes an AMT, unless otherwise agreed with or mandated by a specific jurisdiction.