Common use of Allocation Between Assignor and Assignee Clause in Contracts

Allocation Between Assignor and Assignee. The portion of the income, gain, losses, credits, and deductions of the Company for any Fiscal Year of the Company during which a Membership Interest is assigned by a Member (or by an assignee or successor in interest to a Member), that is allocable with respect to such Membership Interest will be apportioned between the assignor and the assignee of the Membership Interest on whatever reasonable, consistently applied basis selected by the Manager and permitted by the applicable Treasury Regulations under Section 706 of the Code.

Appears in 2 contracts

Samples: Operating Agreement (Claxson Interactive Group Inc), Operating Agreement (Playboy Enterprises Inc)

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Allocation Between Assignor and Assignee. The portion of the income, gain, losses, credits, and deductions of the Company for any Fiscal Year of the Company during which a Membership Percentage Interest is assigned by a Member (or by an assignee or successor in interest to a Member), that is allocable with respect to such Membership Percentage Interest will be apportioned between the assignor and the assignee of the Membership Percentage Interest on whatever reasonable, consistently applied basis is selected by the Manager Executive Board and permitted by the applicable Treasury Regulations under Section 706 of the Code.

Appears in 2 contracts

Samples: Employment Agreement (Simon Worldwide Inc), Employment Agreement (Simon Worldwide Inc)

Allocation Between Assignor and Assignee. The portion of the income, gain, losses, credits, and deductions of the Company for For any Fiscal Year of the Company during which a Membership Interest Unit is assigned by a Member (or by an assignee or successor in interest to a Member), the portion of the income, gain, losses, credits, and deductions of the Company that is allocable with respect to such Membership Interest will Unit shall be apportioned between the assignor and the assignee of the Membership Interest Unit on whatever the basis of an interim closing of the books, unless the Members agree to some other reasonable, consistently applied basis selected by the Manager and permitted by the applicable Treasury Regulations under Section 706 of the Code.

Appears in 1 contract

Samples: Limited Liability Company Agreement (Euroseas Ltd.)

Allocation Between Assignor and Assignee. The portion of the income, gain, losses‎losses, credits‎‎credits, and deductions of the Company for any Fiscal Year during a portion of the Company during a Fiscal Year in which a Member’s Membership Interest is assigned ‎assigned by a Member ‎such ‎Member (or by an assignee or successor in interest to a Member), ) that is allocable ‎allocable with respect ‎respect to such ‎such Membership Interest will be apportioned between the assignor and the assignee of the Membership Interest ‎assignee on whatever reasonable‎whatever ‎reasonable, consistently applied basis is selected by the Manager ‎Managers and permitted by the applicable ‎applicable Treasury Regulations ‎Regulations under Section 706 of the Code.Code.‎

Appears in 1 contract

Samples: Limited Liability Company Agreement (CQENS Technologies Inc.)

Allocation Between Assignor and Assignee. The portion of the income, gain, losses, credits, and deductions of the Company for any Fiscal Year of the Company fiscal year during which a Membership Interest is assigned by a Member (or by an assignee or successor in interest to a Member), that is allocable with respect to such Membership Interest will be apportioned between the assignor and the assignee of the Membership Interest on whatever reasonable, consistently applied basis is selected by the Manager Tax Matters Member and permitted by the applicable Treasury Regulations under Section 706 of the Code.

Appears in 1 contract

Samples: Limited Liability Company Agreement (Genius Products Inc)

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Allocation Between Assignor and Assignee. The portion of the income, gain, losses, credits, and deductions of the Company for any Fiscal Year of the Company during which a Membership Interest is assigned by a Member (or by an assignee or successor in interest to a Member), that is allocable with respect to such Membership Interest will shall be apportioned between the assignor and the assignee of the Membership Interest on whatever reasonable, consistently applied basis selected by the Manager and permitted by the applicable Treasury Regulations under Section 706 of the Code.

Appears in 1 contract

Samples: Operating Agreement (Playboy Enterprises Inc)

Allocation Between Assignor and Assignee. The portion ---------------------------------------- of the income, gain, losses, credits, losses and deductions of the Company for any Fiscal Year of the Company during which a Membership an Interest is assigned by a Member (or by an assignee or successor in interest to a Member), that is allocable with respect to such Membership Interest will be apportioned between the assignor and the assignee of the Membership Interest on whatever reasonable, consistently applied basis selected by the Manager Board and permitted by the applicable Treasury Regulations under Section 706 of the Code.

Appears in 1 contract

Samples: Operating Agreement (Amerigon Inc)

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