Allocation of Income, Gains and Losses. Except as the Partners may determine otherwise in order to comply with the Internal Revenue Code and the regulations thereunder, all items of Partnership income, gains, losses, deductions and credits shall be allocated among the Partners on the day each such item is actually received, accrued or realized by the Partnership in accordance with each Partner's Percentage Interest on such date. The amount of depreciation on property of the Partnership and taxable gain or loss upon the sale of any property of the Partnership shall be allocated so as to take proper account of the difference between the adjusted tax basis of the property to the Partnership and the value of the property as determined under Article 4.2.
Allocation of Income, Gains and Losses. The Company shall initially be a disregarded entity for federal tax purposes and all items of income, gain, loss and deduction shall be allocated to its sole member.
Allocation of Income, Gains and Losses. DISTRIBUTIONS The income, profits, gains, losses and tax credits of the Company and distributions of cash or property of the Company to the Member shall be treated for federal income tax purposes as if the Company were a division of the Member in accordance with Treasury Regulation Section 301.7701-2(a).
Allocation of Income, Gains and Losses. All income, gains, losses, deductions and credits of the Company shall be computed as of the end of each fiscal year of the Company in accordance with the accrual method of accounting, which shall be followed by the Company for federal income tax purposes. Except as otherwise provided in this Article IX, the income, gains, losses, deductions and credits of the Company for each fiscal year for book purposes, whether taxable or non-taxable, shall be allocated to each Member pro rata in accordance with the cash and property distributed to each Member in such fiscal year, if any, and if there is no cash or property distributed, then pro rata in accordance with the Capital Accounts for each Member.
Allocation of Income, Gains and Losses. Distributions ------------- The income, profits, gains, losses and tax credits of the Company and distributions of cash or property of the Company to the Member shall be treated for federal income tax purposes as if the Company were a division of the Member in accordance with Treasury Regulation Section 301.7701-2(a).
Allocation of Income, Gains and Losses. The income, profits, gains, losses, and tax credits of the Company and distributions of cash or property of the Company to the Member shall be treated for United States federal income tax purposes as if the Company were a sole proprietorship, branch or division of the Member, as applicable, in accordance with Treasury Regulation Section 301.7701-2(a).
Allocation of Income, Gains and Losses. Except to the extent provided in the following sentence, each Portfolio will allocate income and realized and unrealized capital gains and losses to a Class based on the relative net assets of each Class. Notwithstanding the foregoing, each Portfolio that declares dividends on a daily basis will allocate income on the basis of settled shares.
Allocation of Income, Gains and Losses. Net capital gain or loss of an Investment Partnership for each year will be allocated 80% to its Investors pro rata in proportion to their committed capital and 20% to the General Partner; provided that to the extent that an allocation of net capital loss would cause the General Partner’s capital account to be less than 0.2% (or such other applicable capital percentage) of the positive capital account balances of all Investors for such Investment Partnership (excluding allocations made to the General Partner’s capital account with respect to the General Partner’s 20% profits interest), such net capital loss (a “Contingent Loss”) will be reallocated to the Investors in proportion to their contributed capital. To the extent the Investors have been allocated Contingent Losses, subsequent net capital gains will be allocated first to the Investors until such Contingent Losses have been restored and then in accordance with the first sentence hereof. Net ordinary gain or loss, including the expense of the management fee and other expenses, will be allocated to the Investors pro rata in proportion to their committed capital.
Allocation of Income, Gains and Losses. DISTRIBUTIONS -------------------------------------------------------
Allocation of Income, Gains and Losses. 8.1 [Intentionally Omitted.]
