Allocation of Income or Loss  or Resource Deduction for Tax Purposes Sample Clauses

Allocation of Income or Loss  or Resource Deduction for Tax Purposes. The income or loss of the Partnership for the whole of a Fiscal Year for the purpose of the Tax Act shall be allocated among the Partners as of the times and in the proportions set out in Sections 12.2 and 13.1. Resource related deductions in subdivision e of part I of the Tax Act , such as Canadian development expense and Canadian exploration expense, shall be allocated to the Partners in the proportions set out in Section 12.2. In the event of a disposition of the Kami Project by the Partnership, all income and/or gain (for the purposes of the Tax Act),(including for greater certainty any proceeds that will reduce "Canadian development expense" (as defined in the Tax Act) of Alderon, in respect of such disposition, to the extent realized solely as a result of the election under subsection 97(2) of the Tax Act described in Section 3.10, shall be allocated solely to Alderon for the purposes of the Tax Act (and any corresponding provisions of any applicable provincial legislation). For greater certainty, the amount of income/gain allocated to Alderon pursuant to this paragraph will not exceed the fair market value of the Kami Project in respect of which such election was made, as determined at the time of transfer of the Kami Project to the Partnership. any additional income/gains shall be allocated amongst the partners in accordance with this Section 12.4.
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Related to Allocation of Income or Loss  or Resource Deduction for Tax Purposes

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

  • 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 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.

  • Net Loss After giving effect to the special allocations set forth in Section 6.1(d), Net Loss for each taxable period and all items of income, gain, loss and deduction taken into account in computing Net Loss for such taxable period shall be allocated as follows:

  • 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:

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

  • Adjustments for Tax Purposes Any payments made pursuant to Section 2.04 shall be treated as an adjustment to the Purchase Price by the parties for Tax purposes, unless otherwise required by Law.

  • Allocation of Nonrecourse Deductions Nonrecourse Deductions shall be allocated to the Members in accordance with their respective Percentage Interests.

  • Net Losses After giving effect to the special allocations set forth in Section 6.1(d), Net Losses for each taxable period and all items of income, gain, loss and deduction taken into account in computing Net Losses for such taxable period shall be allocated as follows:

  • Apportionment of Earnings and Profits and Tax Attributes (a) Tax Attributes arising in a Pre-Distribution Period will be allocated to (and the benefits and burdens of such Tax Attributes will inure to) the members of the Parent Group and the members of the SpinCo Group in accordance with the Code, Treasury regulations and any other Applicable Tax Law, and, in the absence of controlling legal authority or unless otherwise provided under this Agreement, Tax Attributes shall be allocated to the legal entity that created such Tax Attributes.

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