General Method. Except as provided in Section 3.1(b), Tax Items of the Cal Dive Group Members shall be apportioned between Pre-IPO Periods and Post-IPO Periods in accordance with the principles of Treasury Regulations Section 1.1502-76(b) or an applicable corresponding provision under the Tax Laws of any state, local or foreign jurisdiction, as such corresponding provision is reasonably interpreted and applied by Parent. No election shall be made under Treasury Regulations Section 1.1502-76(b)(2)(ii) (relating to ratable allocation of a year’s items).
Appears in 3 contracts
Sources: Tax Matters Agreement (Cal Dive International, Inc.), Tax Matters Agreement (Cal Dive International, Inc.), Tax Matters Agreement (Helix Energy Solutions Group Inc)