Allocation of Tax Credits, Tax Credit Recapture, Etc. Allocations of Tax credits, Tax credit recapture, and any items related thereto shall be allocated to the Unitholders according to their interests in such items as determined by the Manager taking into account the principles of Treasury Regulation Section 1.704-1(b)(4)(ii) and (viii).
Appears in 9 contracts
Samples: Limited Liability Company Agreement (Allvue Systems Holdings, Inc.), Limited Liability Company Agreement (Powerschool Holdings, Inc.), Limited Liability Company Agreement (Powerschool Holdings, Inc.)
Allocation of Tax Credits, Tax Credit Recapture, Etc. Allocations of Tax credits, Tax tax credit recapture, and any items related thereto shall be allocated to the Unitholders Members according to their interests in such items as determined by the Manager Board, taking into account the principles of Treasury Regulation Section 1.704-1(b)(4)(ii) and (viii).
Appears in 6 contracts
Samples: Limited Liability Company Agreement (PF2 SpinCo, Inc.), Limited Liability Company Agreement (Change Healthcare Inc.), Limited Liability Company Agreement (Change Healthcare Inc.)
Allocation of Tax Credits, Tax Credit Recapture, Etc. Allocations of Tax credits, Tax credit recapture, and any items related thereto shall be allocated to the Unitholders according to their interests in such items as determined by the Manager Board taking into account the principles of Treasury Regulation Section 1.704-1(b)(4)(ii) and (viii).
Appears in 4 contracts
Samples: Limited Liability Company Agreement (loanDepot, Inc.), Limited Liability Company Agreement (loanDepot, Inc.), Limited Liability Company Agreement (loanDepot, Inc.)
Allocation of Tax Credits, Tax Credit Recapture, Etc. Allocations of Tax tax credits, Tax tax credit recapture, and any items related thereto shall be allocated to the Unitholders Partners according to their interests Interests in such items as determined by the Manager General Partner taking into account the principles of Treasury Regulation Section 1.704-1(b)(4)(ii) and (viii).
Appears in 3 contracts
Samples: Limited Partnership Agreement (Sanchez Energy Corp), Securities Purchase Agreement (Sanchez Energy Corp), Securities Purchase Agreement (Sanchez Energy Corp)
Allocation of Tax Credits, Tax Credit Recapture, Etc. Allocations of Tax credits, Tax credit recapture, and any items related thereto shall be allocated to the Unitholders according to their interests in such items as determined by the Manager Managing Member taking into account the principles of Treasury Regulation Section 1.704-1(b)(4)(ii) and (viii).
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Real Good Food Company, Inc.), Limited Liability Company Agreement (Real Good Food Company, Inc.), Limited Liability Company Agreement (Real Good Food Company, Inc.)
Allocation of Tax Credits, Tax Credit Recapture, Etc. Allocations of Tax credits, Tax tax credit recapture, and any items related thereto shall be allocated to the Unitholders Members according to their interests in such items as determined by the Manager Managing Member taking into account the principles of Treasury Regulation Section 1.704-1(b)(4)(ii) and (viii).
Appears in 2 contracts
Samples: Reorganization Agreement (Goosehead Insurance, Inc.), Reorganization Agreement (Goosehead Insurance, Inc.)
Allocation of Tax Credits, Tax Credit Recapture, Etc. Allocations of Tax credits, Tax credit recapture, and any items related thereto shall be allocated to the Unitholders according to their interests in such items as determined by the Manager taking into account the principles of Treasury Regulation Section 1.704-1(b)(4)(ii) and (viii).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Clearwater Analytics Holdings, Inc.), Limited Liability Company Agreement (Clearwater Analytics Holdings, Inc.)
Allocation of Tax Credits, Tax Credit Recapture, Etc. Allocations of Tax credits, Tax credit recapture, and any items related thereto shall be allocated to the Unitholders according to their interests in such items as determined by the Manager Board taking into account the principles of Treasury Regulation Section 1.704-1(b)(4)(ii) and (viii).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Vivid Seats Inc.), Transaction Agreement (Horizon Acquisition Corp)
Allocation of Tax Credits, Tax Credit Recapture, Etc. Allocations of Tax credits, Tax credit recapture, and any related items related thereto shall be allocated to the Unitholders according to their interests in such items as determined by the Manager taking into account the principles of Treasury Regulation Section 1.704-1(b)(4)(ii) and (viii).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Bitcoin Depot Inc.), Limited Liability Company Agreement (GSR II Meteora Acquisition Corp.)
Allocation of Tax Credits, Tax Credit Recapture, Etc. Allocations of Tax tax credits, Tax tax credit recapture, and any items related thereto shall be allocated to the Unitholders according to their interests in such items as determined by the Manager Board taking into account the principles of Treasury Regulation Section 1.704-1(b)(4)(ii) and (viii).
Appears in 2 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement
Allocation of Tax Credits, Tax Credit Recapture, Etc. Allocations of Tax tax credits, Tax tax credit recapture, and any items related thereto shall be allocated to the Unitholders Members according to their interests in such items as reasonably determined by the Manager Board taking into account the principles of Treasury Regulation Section 1.704-1(b)(4)(ii) and (viii).
Appears in 1 contract
Allocation of Tax Credits, Tax Credit Recapture, Etc. Allocations of Tax tax credits, Tax tax credit recapture, and any items related thereto shall be allocated to the Unitholders Members according to their interests in such items as determined by the Manager Board of Managers taking into account the principles of Treasury Regulation Section 1.704-1(b)(4)(ii) and (viii).
Appears in 1 contract
Allocation of Tax Credits, Tax Credit Recapture, Etc. Allocations of Tax credits, Tax credit recapture, and any related items related thereto shall be allocated to the Unitholders according to their interests in such items as determined by the Manager Managing Member taking into account the principles of Treasury Regulation Section 1.704-1(b)(4)(ii) and (viii).
Appears in 1 contract
Samples: Limited Liability Company Agreement (GSR II Meteora Acquisition Corp.)
Allocation of Tax Credits, Tax Credit Recapture, Etc. Allocations of Tax credits, Tax credit recapture, and any items related thereto shall be allocated to the Unitholders according to their interests in such items as determined by the Manager Board taking into account the principles of Treasury Regulation Section 1.704-1(b)(4)(ii) and (viii1(b)(4)(ii)and(viii).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Vivid Seats Inc.)
Allocation of Tax Credits, Tax Credit Recapture, Etc. Allocations of Tax tax credits, Tax tax credit recapture, and any items related thereto shall be allocated to the Unitholders according to their interests in such items as determined by the Manager taking into account the principles of Treasury Regulation Section Regulations Sections 1.704-1(b)(4)(ii), 1.704-1(b)(4)(xi) and (viii1.704-1T(b)(4)(xi).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Chicago Pacific Founders UGP, LLC)
Allocation of Tax Credits, Tax Credit Recapture, Etc. Allocations of Tax credits, Tax tax credit recapture, and any items related thereto shall be allocated to the Unitholders Members according to their interests in such items as determined by the Manager Partnership Representative, taking into account the principles of Treasury Regulation Section 1.704-1(b)(4)(ii) and (viii).
Appears in 1 contract
Allocation of Tax Credits, Tax Credit Recapture, Etc. Allocations of Tax credits, Tax credit recapture, and any items related thereto shall be allocated to the Unitholders Members according to their interests in such items as determined by the Manager Board taking into account the principles of Treasury Regulation Regulations Section 1.704-1(b)(4)(ii) and (viii).
Appears in 1 contract
Allocation of Tax Credits, Tax Credit Recapture, Etc. Allocations of Tax tax credits, Tax tax credit recapture, and any items related thereto shall be allocated to the Unitholders according to their interests in such items as determined by the Manager Board taking into account the principles of Treasury Regulation Section Regulations Sections 1.704-1(b)(4)(ii), 1.704-1(b)(4)(xi) and (viii1.704-1T(b)(4)(xi).
Appears in 1 contract
Samples: Limited Liability Company Agreement (ChromaDex Corp.)
