Allocation of Income and Loss for Income Tax Purposes Sample Clauses

Allocation of Income and Loss for Income Tax Purposes. (a) The income and loss for tax purposes of the Partnership for each Fiscal Year shall be computed in accordance with the Tax Act after reimbursement for all costs and expenses incurred by a Partner for and on behalf of the Partnership in accordance with this Agreement and any other applicable taxation or other applicable legislation or similar laws of Canada or of any province or jurisdiction, and shall be allocated at the end of the Fiscal Year to the Persons who were Partners of the Partnership during that Fiscal Year based on the Partner’s Annual Distribution Entitlement for the Fiscal Year.
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Allocation of Income and Loss for Income Tax Purposes. The income, deductions, gains, losses and credits of the Partnership shall be allocated for federal, state and local income tax purposes among the Persons who were Partners during the relevant taxable year in accordance with such Partners' interests, applicable provisions of the Code and other applicable law and administrative pronouncements (including Sections 704(b) and (c) of the Code), taking into account the Partners' Capital Accounts for such year and any variations therein, any distributions by the Partnership, any reimbursement of expenses of any Partner, any additional Capital Contributions and the differences between income for tax purposes and profitability for Partnership accounting purposes.
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Allocation of Income and Loss for Income Tax Purposes. (a) The taxable year of the Partnership shall be the calendar year. The General Partner shall have authority to change the taxable year of the Partnership if the General Partner, in its sole discretion, subject to approval of the Internal Revenue Service, shall determine such change to be necessary or appropriate to the business of the Partnership. The General Partner shall give notice of any such change to the Limited partners in the first quarterly or annual report delivered to the Partners after such change.
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Allocation of Income and Loss for Income Tax Purposes. (a) The income, deductions, gains, losses, and credits of the Partnership shall be allocated for federal, state, and local income tax purposes by the General Partner among the Persons who were Partners during the relevant taxable year. For purposes of determining the income, loss, or any other item allocable to any period during the relevant taxable year of the Partnership, such items shall be determined by the General Partner using any method permitted by Code section 706 and the Treasury Regulations promulgated thereunder. The General Partner shall make all allocations taking into account the Partners’ Capital Accounts on the first day of the relevant taxable year and distributive shares of Net Profit, Net Loss, and special allocations for such year, any entry of new Partners, any distributions by the Partnership, and the difference between income for tax purposes and profitability for Partnership purposes, so that, as closely as reasonably possible, the tax allocations follow the allocations made for “book purposes” under this Agreement; provided, that no such allocation by the General Partner shall discriminate unfairly against any Partner.
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Related to Allocation of Income and Loss for Income Tax Purposes

  • Allocation of Net Income and Net Loss Net Income or Net Loss of the Partnership shall be determined as of the end of each calendar year and as of the end of any interim period extending through the day immediately preceding any (i) disproportionate Capital Contribution, (ii) disproportionate distribution, (iii) Transfer of a Partnership Interest in accordance with the terms of this Agreement, or (iv) Withdrawal Event. If a calendar year includes an interim period, the determination of Net Income or Net Loss for the period extending through the last day of the calendar year shall include only that period of less than twelve (12) months occurring from the day immediately following the last day of the latest interim period during the calendar year and extending through the last day of the calendar year. For all purposes, including income tax purposes, Net Income, if any, of the Partnership for each calendar year or interim period shall be allocated among the Partners in proportion to their respective Partnership Percentages for the calendar year or interim period. In the event of a Net Loss for a particular calendar year or interim period, then, for such calendar year or interim period, the Net Loss for such calendar year or interim period shall be allocated among the Partners in proportion to their respective Partnership Percentages for the calendar year or interim period.

  • Allocations of Income and Loss For each taxable year, each holder of Preferred Units will be allocated a portion of the Net Income and Net Loss of the Partnership equal to the portion of the Net Income and Net Loss of the Partnership that would be allocated to such holder pursuant to Article 6 of the Agreement if such holder held a number of Partnership Common Units equal to (i) the number of Preferred Units held by such holder, multiplied by (ii) 0.5. Upon liquidation, dissolution or winding up of the Partnership, the Partnership shall endeavor to allocate income and gain to the holders of the Preferred Units such that the Capital Accounts related to the Preferred Units are equal to their Liquidation Preference.

  • Allocations for Tax Purposes (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.

  • Allocation of Profits and Losses The Company’s profits and losses shall be allocated to the Member.

  • Allocation of Profit and Loss Article V, Section 5.01 of the Partnership Agreement is hereby deleted in its entirety and the following new Section 5.01 is inserted in its place:

  • Allocations of Net Income and Net Loss Except as otherwise provided in this Agreement, after giving effect to the special allocations in subparagraph 1(c) and paragraph 2, Net Income, Net Loss and, to the extent necessary, individual items of income, gain, loss or deduction, of the Partnership for each fiscal year or other applicable period of the Partnership shall be allocated among the General Partner and Limited Partners in accordance with their respective Percentage Interests.

  • Allocation of Tax Items To the extent permitted by section 1.704-1(b)(4)(i) of the Treasury Regulations, all items of income, gain, loss and deduction for federal and state income tax purposes shall be allocated to the Members in accordance with the corresponding "book" items thereof; however, all items of income, gain, loss and deduction with respect to Assets with respect to which there is a difference between "book" value and adjusted tax basis shall be allocated in accordance with the principles of section 704(c) of the IRS Code and section 1.704-1(b)(4)(i) of the Treasury Regulations, if applicable. Where a disparity exists between the book value of an Asset and its adjusted tax basis, then solely for tax purposes (and not for purposes of computing Capital Accounts), income, gain, loss, deduction and credit with respect to such Asset shall be allocated among the Members to take such difference into account in accordance with section 704(c)(i)(A) of the IRS Code and Treasury Regulation section 1.704-1(b)(4)(i). The allocations eliminating such disparities shall be made using any reasonable method permitted by the Code, as determined by the Manager.

  • Allocation of Profit or Loss All Profit or Loss shall be allocated to the Member.

  • Allocations of Profits and Losses Except as otherwise provided in this Agreement, Profits and Losses (and, to the extent necessary, individual items of income, gain or loss or deduction of the Partnership) shall be allocated in a manner such that the Capital Account of each Partner after giving effect to the Special Allocations set forth in Section 5.05 is, as nearly as possible, equal (proportionately) to (i) the distributions that would be made pursuant to Article IV if the Partnership were dissolved, its affairs wound up and its assets sold for cash equal to their Carrying Value, all Partnership liabilities were satisfied (limited with respect to each non-recourse liability to the Carrying Value of the assets securing such liability) and the net assets of the Partnership were distributed to the Partners pursuant to this Agreement, minus (ii) such Partner’s share of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain, computed immediately prior to the hypothetical sale of assets. For purposes of this Article V, each Unvested Unit shall be treated as a Vested Unit. Notwithstanding the foregoing, the General Partner shall make such adjustments to Capital Accounts as it determines in its sole discretion to be appropriate to ensure allocations are made in accordance with a partner’s interest in the Partnership.

  • Allocation of Overhead To the extent that Borrower, on the one hand, and the Servicer, the Parent, the Performance Guarantor, any Originator or any Affiliate thereof, on the other hand, have offices in the same location, there shall be a fair and appropriate allocation of overhead costs between them, and the Borrower shall bear its fair share of such expenses, which may be paid through the Servicing Fee or otherwise.

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