Common use of Applicable Principles for Exchange Basis and Reorganization Transferred Basis Clause in Contracts

Applicable Principles for Exchange Basis and Reorganization Transferred Basis. For the avoidance of doubt, the Realized Tax Benefit (or the Realized Tax Detriment) attributable to the Exchange Basis or Reorganization 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 in excess of Tax deductions resulting from the IPO Basis. Any Tax Benefit Payments attributable to the Exchange Basis or Reorganization Transferred Basis are intended to be Attributable to, and allocated and paid to, the relevant TRA Parties proportionately based on the Basis Sharing Percentage of each such TRA Party.

Applicable Principles for Exchange Basis and Reorganization Transferred Basis. For the avoidance of doubt, the Realized Tax Benefit (or the Realized Tax Detriment) attributable to the Exchange Basis or Reorganization 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 in excess of Tax deductions resulting from the IPO Basis. Any Tax Benefit Payments attributable to the Exchange Basis or Reorganization Transferred Basis are intended to be Attributable to, and allocated and paid to, the relevant TRA Parties proportionately based on the Basis Sharing Percentage of each Previously Taxed Capital delivered by such TRA PartyParty in the applicable Exchange or in the Reorganization.