Section 338 Allocation definition
Examples of Section 338 Allocation in a sentence
Parent shall provide the allocation to Northrop Grumman no later than Parent provides the Section 338 Allocation to Northrop Grumman under Section 11.5(c), and Northrop Grumman shall provide reasonable comments thereon to Parent within 30 days of receipt thereof.
The Acquiror shall prepare such Tax Returns in accordance with the past practice of the Company and the Transferred Subsidiaries (except as otherwise required by applicable Law, the Section 338(h)(10) Election or the final Section 338 Allocation Schedule) and shall deliver any such Tax Returns that relate to Income Taxes (“Income Tax Returns”) to the Parent for its review at least thirty (30) days prior to the due date (taking into account all extensions properly obtained) for filing.
The Parent and the Purchaser agree to consult and resolve in good faith any issue arising as a result of the Section 338 Allocation Schedule and the IRS Forms 8883, and to mutually consent to the filing as promptly as possible of the IRS Forms 8883.
The Seller and the Purchaser agree to file, and cause their Affiliates to file, all US Tax Returns (if any) in accordance with the Section 338 Allocation Schedule, unless otherwise required by applicable Law.
The Parent and AerCap agree to consult and resolve in good faith any issue arising as a result of the Asset Allocation Schedule, any Section 338 Allocation Schedule and the IRS Forms 8883, and to mutually consent to the filing as promptly as possible of the IRS Forms 8883.