Common use of Allocation of Profits and Losses Clause in Contracts

Allocation of Profits and Losses. The Company's profits and losses shall be allocated entirely to the Member, and the Member's distributive share of income, gain, loss, deduction, or credit (or item thereof) shall be determined and allocated in accordance with this Section 8 to the fullest extent permitted by Sections 704(b) and (c) of the Internal Revenue Code of 1986, as amended, and the treasury regulations promulgated thereunder.

Appears in 11 contracts

Samples: Limited Liability Company Agreement (American Barge Line Co), Limited Liability Company Agreement (American Barge Line Co), Limited Liability Company Agreement (American Barge Line Co)

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Allocation of Profits and Losses. The Company's ’s profits and losses shall be allocated entirely to the Member, and the Member's ’s distributive share of income, gain, loss, deduction, or credit (or item thereof) shall be determined and allocated in accordance with this Section 8 7 to the fullest extent permitted by Sections §§ 704(b) and (c) of the Internal Revenue Code of 1986, as amended, and the treasury regulations promulgated thereunder.

Appears in 10 contracts

Samples: Limited Liability Company Agreement (Atlantic Broadband Management, LLC), Limited Liability Company Agreement (Language Line Costa Rica, LLC), Limited Liability Company Agreement (Atlantic Broadband Management, LLC)

Allocation of Profits and Losses. The Company's profits and losses shall be allocated entirely among the members in proportion to the Member, and number of Units held by each member. It is the Memberintent of the members that each member's distributive share of income, gain, loss, deduction, or credit (or item thereof) shall be determined and allocated in accordance with this Section Paragraph 8 to the fullest extent permitted by Sections 704(b) and (c) of the Internal Revenue Code of 1986, as amended, and the treasury regulations Treasury Regulations promulgated thereunder.

Appears in 10 contracts

Samples: Limited Liability Company Agreement (Ticketmaster Corp /Il/), Limited Liability Company Agreement (Ticketmaster Corp /Il/), Limited Liability Company Agreement (Ticketmaster Corp /Il/)

Allocation of Profits and Losses. The Company's ’s profits and losses shall be allocated entirely to the Member, and the Member's ’s distributive share of income, gain, loss, deduction, or credit (or item thereof) shall be determined and allocated in accordance with this a manner that as closely as possible gives economic effect to Section 8 7 to the fullest extent permitted by Sections §§ 704(b) and (c) of the Internal Revenue Code of 1986, as amended, and the treasury regulations promulgated thereunder.

Appears in 4 contracts

Samples: Limited Liability Company Agreement (IDQ Operating, Inc.), Limited Liability Company Agreement (IDQ Operating, Inc.), Limited Liability Company Agreement (Armored AutoGroup Inc.)

Allocation of Profits and Losses. The Company's profits and losses shall be allocated entirely among the members in proportion to the Member, and number of Units held by each member. It is the Memberintent of the members that each member's distributive share of income, gain, loss, deduction, or credit (or item thereof) shall be determined and allocated in accordance with this Section Paragraph 8 to the fullest extent permitted by Sections 704(b704 (b) and (c) of the Internal Revenue Code of 1986, as amended, and the treasury regulations Treasury Regulations promulgated thereunder.

Appears in 3 contracts

Samples: Limited Liability Company Agreement (Ticketmaster Corp /Il/), Limited Liability Company Agreement (Ticketmaster Corp /Il/), Limited Liability Company Agreement (Ticketmaster Corp /Il/)

Allocation of Profits and Losses. The Company's profits and losses shall be allocated entirely to the Member, and the Member's distributive share of income, gain, loss, deduction, or credit (or item thereof) shall be determined and allocated in accordance with this Section 8 10 to the fullest extent permitted by Sections 704(b) and (c) of the Internal Revenue Code of 1986, as amended, and the treasury regulations promulgated thereunder.

Appears in 3 contracts

Samples: Limited Liability Company Agreement (American Commercial Lines LLC), Operating Agreement (Donjoy LLC), Limited Liability Company Agreement (Acl Capital Corp)

Allocation of Profits and Losses. The Company's profits and losses shall be allocated entirely among the members in proportion to the Member, and number of Units held by each member. It is the Memberintent of the members that each member's distributive share of income, gain, loss, deduction, or credit (or item thereof) shall be determined and allocated in accordance with this Section Paragraph 8 to the fullest extent permitted by Sections Section 704(b) and (c) of the Internal Revenue Code of 1986, as amended, and the treasury regulations Treasury Regulations promulgated thereunder.

Appears in 2 contracts

Samples: Limited Liability Company Agreement (Ticketmaster Corp /Il/), Limited Liability Company Agreement (Ticketmaster Corp /Il/)

Allocation of Profits and Losses. The Company's profits and losses shall be allocated entirely to the Member, and the Member's distributive share of income, gain, loss, deduction, or credit (or item thereof) shall be determined and allocated in accordance with this Section 8 6 to the fullest extent permitted by Sections 704(bss.ss.704(b) and (c) of the Internal Revenue Code of 1986, as amended, and the treasury regulations promulgated thereunder.

Appears in 1 contract

Samples: Merger Agreement (Dj Orthopedics Capital Corp)

Allocation of Profits and Losses. The Company's profits and losses shall be allocated entirely among the members in proportion to the Member, and number of Units held by each member. It is the Memberintent of the members that each member's distributive share shares of income, gain, loss, deduction, or credit (or item thereof) shall be determined and allocated in accordance with this Section Paragraph 8 to the fullest extent permitted by Sections 704(b) and (c) of the Internal Revenue Code of 1986, as amended, and the treasury regulations Treasury Regulations promulgated thereunder.

Appears in 1 contract

Samples: Limited Liability Company Agreement (Ticketmaster Corp /Il/)

Allocation of Profits and Losses. The Company's profits and losses shall be allocated entirely among the members in proportion to the Member, and number of Units held by each member. It is the Member's intent of the members that each member"s distributive share of income, gain, loss, deduction, or credit (or item thereof) shall be determined and allocated in accordance with this Section Paragraph 8 to the fullest extent permitted by Sections 704(b) and (c) of the Internal Revenue Code of 1986, as amended, and the treasury regulations Treasury Regulations promulgated thereunder.

Appears in 1 contract

Samples: Limited Liability Company Agreement (Ticketmaster Corp /Il/)

Allocation of Profits and Losses. The Company's profits and losses shall be allocated entirely among the members in proportion to the Member, and number of Units held by each member. It is the Memberintent of the members that each member's distributive share of income, gain, loss, deduction, or credit (or item thereof) thereto shall be determined and allocated in accordance with this Section Paragraph 8 to the fullest extent permitted by Sections 704(b) and (c) of the Internal Revenue Code of 1986, as amended, and the treasury regulations Treasury Regulations promulgated thereunder.

Appears in 1 contract

Samples: Limited Liability Company Agreement (Ticketmaster Corp /Il/)

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Allocation of Profits and Losses. The Company's profits and losses shall be allocated entirely among the members in proportion to the Member, and number of Units held by each member. It is the Memberintent of the members that each member's distributive share of income, gain, loss, deduction, or credit (or item thereof) thereof shall be determined and allocated in accordance with this Section Paragraph 8 to the fullest extent permitted by Sections 704(b) and (c) of the Internal Revenue Code of 1986, as amended, and the treasury regulations Treasury Regulations promulgated thereunder.

Appears in 1 contract

Samples: Limited Liability Company Agreement (Ticketmaster Corp /Il/)

Allocation of Profits and Losses. The Company's profits and losses shall be allocated entirely to the Member, and the Member's distributive share of income, gain, loss, deduction, or credit (or item thereof) shall be determined and allocated in accordance with this Section 8 10 to the fullest extent permitted by Sections §§704(b) and (c) of the Internal Revenue Code of 1986, as amended, and the treasury regulations promulgated thereunder.

Appears in 1 contract

Samples: Operating Agreement (DJO Opco Holdings, Inc.)

Allocation of Profits and Losses. The Company's profits and losses shall be allocated entirely to the Member, and the Member's distributive share of income, gain, loss, deduction, or credit (or item thereof) shall be determined and allocated in accordance with this Section 8 10 to the fullest extent permitted by Sections Section 704(b) and (c) of the Internal Revenue Code of 1986, as amended, and the treasury regulations promulgated thereunder.

Appears in 1 contract

Samples: Limited Liability Company Agreement (Acl Capital Corp)

Allocation of Profits and Losses. The Company's profits and losses shall be allocated entirely to the Member, and the Member's distributive share of income, gain, loss, deduction, or credit (or item thereof) shall be determined and allocated in accordance with this Section 8 to the fullest extent permitted by Sections 704(b) and (c) of the Internal Revenue Code of 1986, as amendedamended (the "Code"), and the treasury regulations promulgated thereunder.

Appears in 1 contract

Samples: Limited Liability Company Agreement (American Barge Line Co)

Allocation of Profits and Losses. The Company's profits and losses shall be allocated entirely to the Member, and the Member's distributive share of income, gain, loss, deduction, or credit (or item thereof) shall be determined and allocated in accordance with this a manner that as closely as possible gives economic effect to Section 8 7 to the fullest extent permitted by Sections §§ 704(b) and (c) of the Internal Revenue Code of 1986, as amended, and the treasury regulations promulgated thereunder.

Appears in 1 contract

Samples: Recapitalization Agreement (Grande Communications Holdings, Inc.)

Allocation of Profits and Losses. The Company's profits and losses shall be allocated entirely to the Member, and the Member's distributive share All items of income, gain, loss, deduction, or deduction and credit (or item thereof) of the Company shall be determined and allocated entirely to the Member in accordance with this Section 8 to the fullest extent permitted by Sections 704(b) and (c) of the Internal Revenue Code of 1986, as amended, and the treasury regulations promulgated U.S. Treasury Regulations thereunder.

Appears in 1 contract

Samples: Limited Liability Company Operating Agreement (Capmark Finance Inc.)

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