Common use of Applicable Principles for Blocker Transferred Basis Clause in Contracts

Applicable Principles for Blocker Transferred Basis. For the avoidance of doubt, the Realized Tax Benefit (or the Realized Tax Detriment) attributable to the Blocker Transferred Basis is intended to represent the decrease (or increase) in the actual liability for Taxes of the Corporate Taxpayer for such Taxable Year attributable to the Tax deductions resulting from the tax basis of the Reference Assets measured at the time of the IPO based on the Blocker Shareholders’ proportionate ownership of the total equity interests of the Blockers and such Blockers’ relative pro rata share in accordance with Units held immediately prior to the Mergers.