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Tax Allocation Agreement
"Need a Tax Allocation Agreement for our parent company and three manufacturing subsidiaries operating across California and Texas, with specific provisions for R&D tax credits and quarterly payment schedules to be implemented from January 2025."
1. Parties: Identification of parent company and subsidiaries involved in the agreement
2. Background: Context of the agreement and relationship between parties
3. Definitions: Key terms used throughout the agreement including tax-specific terminology
4. Tax Sharing Payments: Methodology for calculating and allocating tax liabilities and benefits among group members
5. Payment Terms: Timing, method, and procedures for payments between group members
6. Tax Return Preparation: Responsibilities and procedures for preparing and filing consolidated returns
7. Dispute Resolution: Process for resolving disagreements between parties regarding tax allocations
8. Term and Termination: Duration of the agreement and circumstances for termination
1. State Tax Provisions: Specific provisions for state tax allocation when operating in multiple states
2. Foreign Tax Provisions: Provisions for handling foreign tax credits and liabilities for international operations
3. Regulatory Compliance: Special provisions for regulated entities subject to specific oversight requirements
4. Change in Law Provisions: Procedures for addressing changes in tax laws affecting the agreement
1. Schedule A - Group Members: Comprehensive list of all entities included in the tax sharing agreement
2. Schedule B - Allocation Methodology: Detailed calculations and examples of tax allocation method
3. Schedule C - Payment Procedures: Specific procedures for making and documenting payments
4. Appendix A - Tax Return Filing Schedule: Timeline and deadlines for tax return preparation and filing
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