Allocation for Income Tax Purposes. (a) For federal, state and local income tax purposes, all items of taxable income, gain, loss and deduction for each Fiscal Year or period shall be allocated among the Members in accordance with the manner in which the corresponding items were allocated under Sections 6.03 and 6.04, except as provided in Sections 6.05(b) and 6.05(c) below.
Allocation for Income Tax Purposes. (a) Except as provided in Section 7.05(b), 7.05(c) and 7.05(d), each item of income, gain, loss and deduction of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such items are allocated for book purposes under Sections 7.03 and 7.04.
Allocation for Income Tax Purposes. For income tax purposes, each item of income, gain, loss and deduction of the Company shall be allocated among the Members in any manner, as reasonably determined by the Managing Member that reflects equitably amounts credited or debited to each Member’s Capital Account pursuant to Section 4.7 and Section 4.8 for the current and prior Fiscal Periods. These allocations shall be made pursuant to the general principles of Sections 704(b) and 704(c) of the Code and in accordance with any temporary or final regulations adopted thereunder.
Allocation for Income Tax Purposes. 21 Section 6.06. Other Allocation Rules 22 Section 6.07. Regulatory Compliance 22 Section 6.08. Certain Costs And Expenses 22 ARTICLE 7 MANAGEMENT AND CONTROL OF BUSINESS Section 7.01. Management 23 Section 7.02. Certain Covenants 23 Section 7.03. Investment Company Act 23 ARTICLE 8 OFFICERS Section 8.01. Officers 23 Section 8.02. Other Officers and Agents 24 Section 8.03. Chief Executive Officer 24 Section 8.04. Treasurer 24 Section 8.05. Secretary 24 Section 8.06. Other Officers 24 ARTICLE 9 TRANSFERS OF INTERESTS; ADMITTANCE OF NEW MEMBERS Section 9.01. Transfer of Membership Interests 25 Section 9.02. Transfer of HII’s Interest 25 Section 9.03. Recognition of Transfer; Substituted and Additional Members 25 Section 9.04. Expense of Transfer; Indemnification 27 Section 9.05. Exchange Agreement 27 Section 9.06. Recapitalization 27
Allocation for Income Tax Purposes. Income and losses of the Limited Partnership shall be determined in accordance with the Income Tax Act (Canada).
Allocation for Income Tax Purposes. 16 Section 6.06. Other Allocation Rules 16 Section 6.07. Regulatory Compliance 17 Section 6.08. Certain Costs and Expenses 17
Allocation for Income Tax Purposes. The Members understand that for income tax purposes, the Company’s adjusted basis for the interest in the Property contributed to the capital of the Company pursuant to Sections 2.01 and 2.06 hereof may differ from the value at which the interest was accepted by the Company at the time of its contribution. Nevertheless, the Members intend that allocations shall be governed by Section 704(b) of the Code, to the extent permitted by Section 704(c) of the Code and the regulations thereunder as hereinafter set forth in Section 2.08 hereof.
Allocation for Income Tax Purposes. 17 Section 6.06. Regulatory Compliance. 18 Section 6.07. Tax Matters Member. 18 Section 6.08. Elections. 18 Section 6.09. Change of Members’ Percentage Interests. 19 Section 6.10. Certain Costs And Expenses. 19
Allocation for Income Tax Purposes. (a) Except as provided in this Section 4.3, each item of income, gain, loss and deduction of the Partnership for federal income tax purposes shall be allocated among the Partners in the same manner as such items are allocated for book purposes under Section 4.2. Xxxx-Xxxxxxx Exploration II, L.P. Amended and Restated Agreement of Limited Partnership
Allocation for Income Tax Purposes. Notwithstanding any other provision hereof to the contrary and unless otherwise required or mandated by any applicable Legal Requirement or Order, for income tax purposes, the Purchase Price is net of the following: (i) the portion of the MCG Debt Amount (including accrued and unpaid interest) on the books of and attributable to Dynamic Graphics, Inc., a wholly-owned Subsidiary of Creatas and co-borrower under the MCG Credit Agreement and (ii) the Moffly Change of Control Payment and the Xxxxxxxx Change of Control Payment.
