Allocated Taxable Income. Shall mean, with respect to the AT&T Broadband Group and the AT&T Communications Group, the amount equal to (i) such Group's contribution to the gross income of the AT&T Affiliated Group, net of (ii) the aggregate of all losses, deductions and other Tax attributes of such Group to the extent the same may be used by any member of the AT&T Affiliated Group. For purposes of the federal alternative minimum Tax ("AMT"), Allocated Taxable Income (Loss) shall mean, with respect to the AT&T Broadband
... Group and the AT&T Communications Group, the amount equal to (i) such Group's contribution to the gross income for AMT purposes of the AT&T Affiliated Group, net of (ii) the aggregate of all losses, deductions and other Tax attributes for AMT purposes of such Group to the extent the same may be used by any member of the AT&T Affiliated Group. In the case of any state or local combined, consolidated, or unitary income or franchise Taxes which are required to be reported on a Joint Return, the amount of Allocated Taxable Income (Loss) of the AT&T Broadband Group and the AT&T Communications Group shall be equal to the product of such Group's income (loss) and the apportionment factors (property, payroll, sales), calculated on a consolidated basis, unless such amount is determined pursuant to another allocation method that is agreed with or mandated by a specific jurisdiction. For purposes of the preceding sentence, the apportionment factors shall be determined for each taxable period. In the case of any federal income Tax, AMT, or state or local combined, consolidated or unitary income or franchise Taxes which are required to be reported on a Joint Return, the Allocated Taxable Income (Loss) of the AT&T Communications Group shall include any income or loss that cannot be attributed to any one of the Groups under this Agreement, except as otherwise provided herein or in the Separation and Distribution Agreement. -2-
View More
Allocated Taxable Income. Shall mean, with respect to the Common Stock Group or the Wireless Group, the amount equal to (i) such Group's contribution to the gross income of the Hypothetical Common Stock/Wireless Affiliated Group, net of (ii) the aggregate of all losses, deductions and other Tax attributes of such Group to the extent the same may be used by any member of the Hypothetical Common Stock/Wireless Affiliated Group. For purposes of the federal alternative minimum Tax ("AMT"), Allocated Taxable Income (Loss)
... shall mean, with respect to the Common Stock Group or the Wireless Group, the amount equal to -3- 4 (i) such Group's contribution to the gross income for AMT purposes of the Hypothetical Common Stock/Wireless Affiliated Group, net of (ii) the aggregate of all losses, deductions and other Tax attributes for AMT purposes of such Group to the extent the same may be used by any member of the Hypothetical Common Stock/Wireless Affiliated Group. In the case of any state or local consolidated, combined or unitary income or franchise Taxes which are required to be reported on a Joint Return, the amount of Allocated Taxable Income (Loss) of the Common Stock Group or the Wireless Group shall be equal to the product of such Group's income (loss) and the apportionment factors (property, payroll, sales), calculated on a consolidated basis, unless such amount is determined pursuant to another allocation method that is agreed with or mandated by a specific jurisdiction. For purposes of the preceding sentence, the apportionment factors shall be determined for each taxable period.
View More
