Hyatt Separate Return Basis

Hyatt Separate Return Basis. The Tax liability (including any minimum tax liability), determined at the end of any Taxable Period or Straddle Period, for the Hyatt Members (or any specific Hyatt Member) computed as if such corporations were not part of the Holding Group, but rather a separate Affiliated Group with Hyatt as the common parent. Such computation shall be made without regard to the income, deductions (including net operating loss and capital loss deductions) and credits of any Holding Member or Classic Member.... The income, deductions, credits, carryovers and other tax attributes of the Hyatt Members shall be determined in accordance with all elections used (with the exception of foreign tax credits available) by each Hyatt Member. In calculating Tax liability on the Hyatt Separate Return Basis, the separate taxable income or loss of any Hyatt Member shall be computed as if such member filed a separate income Tax Return for all Taxable Periods or Straddle Periods, except that such member will be allowed to include, without limitation, current capital losses, current Section 1231 losses and current charitable contribution deductions under Section 170, in the computation of its separate taxable income or loss. Such member shall not be entitled to the benefit of any carryover or carry back of any losses or deductions. Any gains or losses on inter-company transactions between Hyatt Members shall not be taken into account. View More