Allocation Between Assignor and Assignee. The portion of the income, gain, losses, credits, and deductions of the Company for any Fiscal Year during which a 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 Percentage Interest will be apportioned between the assignor and the assignee of the Percentage Interest on whatever reasonable, consistently applied basis is selected by the Executive Board and permitted by the applicable Treasury Regulations under Section 706 of the Code.
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Samples: Limited Liability Company Agreement (Simon Worldwide Inc), Limited Liability Company Agreement (Simon Worldwide 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 during which a Percentage 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 Percentage Membership Interest will be apportioned between the assignor and the assignee of the Percentage Membership Interest on whatever reasonable, consistently applied basis is selected by the Executive Board Manager and permitted by the applicable Treasury Regulations under Section 706 of the Code.
Appears in 2 contracts
Samples: Operating Agreement (Playboy Enterprises Inc), Operating Agreement (Claxson Interactive Group 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 during which a Percentage 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 Percentage Membership Interest will shall be apportioned between the assignor and the assignee of the Percentage Membership Interest on whatever reasonable, consistently applied basis is selected by the Executive Board Manager and permitted by the applicable Treasury Regulations under Section 706 of the Code.
Appears in 1 contract
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 a Fiscal Year in which a Percentage 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 Percentage such Membership Interest will be apportioned between the assignor and the assignee of the Percentage Interest assignee on whatever reasonablewhatever reasonable, consistently applied basis is selected by the Executive Board Managers and permitted by the applicable applicable Treasury Regulations Regulations under Section 706 of the Code.Code.
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Samples: Limited Liability Company Agreement (CQENS Technologies Inc.)
Allocation Between Assignor and Assignee. The portion ---------------------------------------- of the income, gain, losses, credits, losses and deductions of the Company for any Fiscal Year during which a Percentage 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 Percentage Interest will be apportioned between the assignor and the assignee of the Percentage Interest on whatever reasonable, consistently applied basis is selected by the Executive Board and permitted by the applicable Treasury Regulations under Section 706 of the Code.
Appears in 1 contract
Samples: Operating Agreement (Amerigon Inc)
Allocation Between Assignor and Assignee. The portion of the income, gain, losses, credits, and deductions of the Company for any Fiscal Year fiscal year during which a Percentage 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 Percentage Membership Interest will be apportioned between the assignor and the assignee of the Percentage Membership Interest on whatever reasonable, consistently applied basis is selected by the Executive Board 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)