Allocation of Taxable Income and Loss. (a) Except as otherwise provided in this Section 4.3, the taxable income or loss of the Company (and items thereof) for any Allocation Period shall be allocated among the Members in proportion to and in the same manner as Net Gain, Net Loss and separate items of income, gain, loss and deduction are allocated among the Members for Capital Account purposes pursuant to the provisions of Section 4.2. Except as otherwise provided in this Section 4.3, the allocable share of a Member for tax purposes in each specified item of income, gain, deduction and loss of the Company comprising Net Gain, Net Loss or an item allocated pursuant to Section 4.2 shall be the same as such Member’s allocable share of Net Gain, Net Loss or the corresponding item for such Fiscal Period.
Allocation of Taxable Income and Loss. (a) Except as otherwise provided in this Section 7.9, the taxable income or loss of the Company for any Accounting Period shall be allocated among the Partners in proportion to and in the same manner as Net Profit, Net Loss and separate items of income, gain, loss and expense (excluding items for which there are no related tax items) are allocated among the Partners for Capital Account purposes pursuant to the provisions of Sections 7.5, 7.6, 7.7 and 7.8 giving effect to Sections 704(b) and (c) of the Code. Except as otherwise provided in this Section 7.9, the allocable share of a Partner for tax purposes in each specified item of income, gain, loss or expense of the Company comprising Net Profit, Net Loss or any item allocated pursuant to Section 7.5, 7.6, 7.7 or 7.8, as the case may be, shall be the same as such Partner's allocable share of Net Profit, Net Loss or the corresponding item for such Accounting Period. To the fullest extent practicable and permitted under the Code, all items of ordinary deduction and income shall be allocated separately from items of capital loss and gain.
Allocation of Taxable Income and Loss. (a) Except as otherwise provided in this Section 7.2, the taxable income or loss of the Company (and items thereof) for any Allocation Period shall be allocated among the Members in proportion to and in the same manner as Net Gain, Net Loss and separate items of income, gain, loss and deduction (excluding items for which there are no related tax items) are allocated among the Members for Capital Account purposes pursuant to the provisions of Section 7.1. Except as otherwise provided in this Section 7.2, the allocable share of a Member for tax purposes in each specified item of income, gain, deduction and loss of the Company comprising Net Gain, Net Loss or an item allocated pursuant to Section 7.1 shall be the same as such Member’s allocable share of Net Gain, Net Loss or the corresponding item for such Allocation Period.
Allocation of Taxable Income and Loss. For federal income tax purposes, items of income, loss, gain and deduction shall be allocated as nearly as possible to the manner in which such items are allocated for purposes of determining Capital Accounts pursuant to Sections 4.2, 4.3 and 4.5.
Allocation of Taxable Income and Loss. For purposes of this Agreement, “net profits” or “net losses” shall be determined as required by the regulations promulgated under IRC 704, as it may be amended from time to time. Taxable Income and Tax Losses of the Company for each fiscal year shall be determined as of the end of each fiscal year and shall be allocated as set forth below and shall be subject to the rules for special allocations set forth in Paragraph 5.4.2.
Allocation of Taxable Income and Loss. The Net Income of the Partnership for the purposes of the Tax Act for each fiscal year (including net income from any sale of property interests) shall be allocated among the Partners based on the same formula as the allocation of Distributable Cash set forth in Section 6.04. The Net Loss of the Partnership for the purposes of the Tax Act for each fiscal year (including loss from any sale of property interests) shall be allocated entirely to the Limited Partners.
Allocation of Taxable Income and Loss. The income, gains, losses, credits and deductions of the Company shall be allocated among the members in the same manner as such items are allocated to the Capital Accounts of the members, to the extent permitted under the Code and applicable Treasury Regulations.
Allocation of Taxable Income and Loss
