Tax Allocation Agreement
This amended and adapted agreement will come into effect on November 21, 2013 between Ameren Corporation, a Missouri Corporation, and its related companies, as set forth in Appendix A (together the “Group”; individually “Affiliate”). Holding companies that have not yet amended their tax-sharing agreements should consider revising them to include the standard language. However, until the Supreme Court considers, lower courts may come to different conclusions as to whether an agreement creates a debtor-to-creditor ratio. A Decision by the Supreme Court could eventually lead to additional regulatory guidance. When several companies are grouped into a large group, the parent company negotiates directly with the IRS, pays the tax debts for the group and receives any refunds. .