Common use of Additional Allocations Clause in Contracts

Additional Allocations. Notwithstanding anything to the contrary in this Agreement, all allocations under this Agreement shall be adjusted insofar as may be required to enable the Partnership to meet the requirements of Section 514(c)(9)(E) of the Code and the Regulations thereunder so that all allocations hereunder have "substantial economic effect" within the meaning of Section 704(b)(2) of the Code and so that, as to each Partner which is a Qualified Organization and the General Partner, (a) each such Partner's percentage share of the Partnership's "overall partnership income" (within the meaning of Section 514(c)(9)(E)(i)(I) of the Code and Regulation Section 1.514(c)-2) shall not, for any taxable year of the Partnership, be greater than the percentage then applicable to such Partner pursuant to Section 5.1 hereof, and (b) each such Partner's percentage share of the Partnership's "overall partnership loss" (within the meaning of Section 514(c)(9)(E)(i)(I) of the Code and Regulation Section 1.514(c)-2) shall not, for any taxable year of the Partnership, be less than the percentage then applicable to such Partner pursuant to Section 5.1 hereof.