Separate Return Basis definition

Separate Return Basis the Tax liability for the Marketing Group (or any Marketing Member) calculated with Marketing as the common parent of the Affiliated Group and without regard to any Realty Members. "Spin-off" -- as defined in the Preamble to this Agreement.
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Separate Return Basis means the computation of Tax for a member of the Consolidated Group on the basis of a separate federal income tax return for the Taxable Year.
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Separate Return Basis the Tax liability for the Marketing Group (or any Marketing Member) calculated with Marketing as the common parent of the Affiliated Group and without regard to any Realty Members. “Spin-off” — as defined in the Preamble to this Agreement. “Straddle Period” — any Taxable Year beginning before and ending after the close of business on the Closing Date. “Tax(es)” — with respect to any corporation or group of corporations, any and all taxes based upon or measured by net income, gross income, gross receipts (when levied in lieu of an income tax) or alternative minimum taxable income, capital or net worth, or motor fuel taxes, regardless of whether denominated as an “income tax,” a “franchise tax” or otherwise, imposed by any Taxing Authority, whether any such tax is imposed directly or through withholding, together with any interest and any penalty, addition to tax or additional amount. “Taxable Period” — a Pre-Closing Taxable Period, a Post-Closing Taxable Period or a Straddle Period. “Taxable Year” — a taxable year (which may be shorter than a full calendar or fiscal year), year of assessment or similar period with respect to which any Tax may be imposed. “Tax Benefit(s)” — (i) in the case of a Tax for which a consolidated federal, or a consolidated, combined or unitary state or other, Tax Return is filed, the amount by which the Tax liability of the Affiliated Group or other relevant group of corporations is actually reduced on a “with and without” basis (by deduction, entitlement to refund, credit, offset or otherwise, whether available in the current Taxable Year, as an adjustment to taxable income in any other Taxable Year or as a carryforward or carryback, and including the effect of such reduction on other Taxes), plus any interest received with respect to any related Tax refund, and (ii) in the case of any other Tax, the amount by which the Tax liability of a corporation is actually reduced on a “with and without” basis (as a result of a deduction, entitlement to refund, credit, offset or otherwise, whether available in the current Taxable Year, or as an adjustment to taxable income in any other Taxable Year or as a carryforward or carryback, and including the effect of such reduction on other Taxes), plus any interest received with respect to any related Tax refund. “Taxing Authority” — the IRS and any other domestic or foreign governmental authority responsible for the administration of any Tax. “Tax Practices” — the most recently applied policies, ...
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Examples of Separate Return Basis in a sentence

  • In the year at issue, the Marathon Stock Group is able to use $100 of MTC on a Separate Return Basis.

  • In 1999, the United States Steel Stock Group generates $100 of losses and the Marathon Stock Group has no income; on a Separate Return Basis, United States Steel would have been able to carry the losses back to 1998, but no such carryback is available on the Tax Returns of the USX Consolidated Group.

  • The United States Steel Stock Group could not have used its net operating losses on a Separate Return Basis.

  • Any item of income or expense that is allocated between the Groups for financial statement purposes shall be allocated in a manner consistent with such financial statements in order to compute taxable income or loss on a Separate Return Basis.

  • In the same year, the USX Consolidated Group utilizes $286 of net operating losses of the United States Steel Stock Group, which under the relevant ordering rules of the Code, preempt and displace in their entirety the $100 of MTC utilized by the Marathon Stock Group on a Separate Return Basis.

  • In 1998, the Marathon Stock Group generates $200 of net operating losses which it is unable to use on a Separate Return Basis; the United States Steel Group generates $100 of income, which on the Tax Return of the USX Consolidated Group is offset by $100 of the Marathon net operating losses.

  • On a Separate Return Basis, the Marathon Stock Group is able to use $100 of MTC, and the United States Steel Stock Group is able to use $40 of MTC.

  • On a Separate Return Basis, the Marathon Stock Group is able to use $100 of MTC, and the United States Steel Stock Group is able to use $50 of MTC.

  • Since in this case each Group has $100 of MTC on a Separate Return Basis, each Group would be deemed to utilize 50% of the total utilized, or $50 of MTC.

  • If AMT Is Payable - If the Consolidated Group's Consolidated Tax Liability is for AMT, the Company's share of such Tax shall be the amount of AMT for which the Company would be liable if computed on a Separate Return Basis (and without regard to the Regular Tax for such Taxable Year), after taking into account all Consolidated Tax Attributes available for such Company to reduce AMT.


More Definitions of Separate Return Basis

Separate Return Basis. With respect to each member, an amount equal to such member's U.S. tax liability for the year determined on a separate return basis.
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Separate Return Basis the Tax liability for the Services Group (or any Services Member) calculated with Services as the common parent of the Affiliated Group and without regard to any Host Marriott Members.
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Separate Return Basis the Tax liability for the Realty Group (or any Realty Member) calculated with Realty as the common parent of the Affiliated Group and without regard to any Culbro Members.
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Separate Return Basis means, with respect to any Taxable Year or portion thereof, (i) in the case of a Tax Liability of the Subsidiary Group, calculated with Subsidiary as the common parent of that Affiliated Group and without regard to any Post-Distribution Parent Group Members; and (ii) in the case of any individual Subsidiary Member, calculated as if such Subsidiary Member were a separate entity outside of any Affiliated Group.
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Related to Separate Return Basis

  • Separate Return means (a) in the case of any Tax Return of any member of the SpinCo Group (including any consolidated, combined or unitary return), any such Tax Return that does not include any member of the Parent Group and (b) in the case of any Tax Return of any member of the Parent Group (including any consolidated, combined or unitary return), any such Tax Return that does not include any member of the SpinCo Group.

  • SpinCo Separate Return means any Tax Return of or including any member of the SpinCo Group (including any consolidated, combined, or unitary return) that does not include any member of the Parent Group.

  • Joint Return means any Return of a member of the Parent Group or the SpinCo Group that is not a Separate Return.

  • Tax return preparer means any individual described in Section 7701(a)(36) of the Internal Revenue Code and 26 C.F.R. 301.7701-15 .

  • Hypothetical Tax Liability means, with respect to any Taxable Year, the Hypothetical Federal Tax Liability for such Taxable Year, plus the Hypothetical Other Tax Liability for such Taxable Year.