Allocation to Reverse Deemed Capital Contributions. Any items of loss or deduction resulting from or relating to the grant of options to acquire stock, or the issuance of stock, by EnLink Midstream, Inc., or from the transfer of any other property by the General Partner or EnLink Midstream, Inc., to or for the benefit of any employee or other service provider of the Partnership, the Operating Partnership, or any of their respective Subsidiaries shall be specially allocated to the General Partner if and to the extent such grant of options, issuance of stock, or transfer of property was treated under applicable tax law as an actual or deemed capital contribution by the General Partner which resulted in an increase to the General Partner’s Capital Account. The items of income, gain, loss and deduction that are included in an aggregate that is allocated pursuant to a provision of this Section 6.1(d) for a taxable period of the Partnership shall be allocated in the ratio that such aggregate was allocated.
Appears in 9 contracts
Samples: Agreement of Limited Partnership (EnLink Midstream, LLC), Limited Partnership Agreement (EnLink Midstream Partners, LP), Limited Partnership Agreement (EnLink Midstream, LLC)
Allocation to Reverse Deemed Capital Contributions. Any items of loss or deduction resulting from or relating to the grant of options to acquire stock, or the issuance of stock, by EnLink MidstreamCrosstex Energy, Inc., or from the transfer of any other property by the General Partner Partner, Crosstex GP, or EnLink MidstreamCrosstex Energy, Inc., to or for the benefit of any employee or other service provider of the Partnership, the Operating Partnership, or any of their respective Subsidiaries shall be specially allocated to the General Partner if and to the extent such grant of options, issuance of stock, or transfer of property was treated under applicable tax law as an actual or a deemed capital contribution by the General Partner which resulted in an increase to the General Partner’s Capital Account. The items of income, gain, loss and deduction that are included in an aggregate that is allocated pursuant to a provision of this Section 6.1(d) for a taxable period of the Partnership shall be allocated in the ratio that such aggregate was allocated.
Appears in 4 contracts
Samples: Senior Subordinated Series C Unit Purchase Agreement (Crosstex Energy Inc), Limited Partnership Agreement (Crosstex Energy Lp), Limited Partnership Agreement (Crosstex Energy Lp)
Allocation to Reverse Deemed Capital Contributions. Any items of loss or deduction resulting from or relating to the grant of options to acquire stock, or the issuance of stock, by EnLink MidstreamCrosstex Energy, Inc., or from the transfer of any other property by the General Partner Partner, Crosstex GP, or EnLink MidstreamCrosstex Energy, Inc., to or for the benefit of any employee or other service provider of the Partnership, the Operating Partnership, or any of their respective Subsidiaries shall be specially allocated to the General Partner if and to the extent such grant of options, issuance of stock, or transfer of property was treated under applicable tax law as an actual or deemed capital contribution by the General Partner which resulted in an increase to the General Partner’s Capital Account. The items of income, gain, loss and deduction that are included in an aggregate that is allocated pursuant to a provision of this Section 6.1(d) for a taxable period of the Partnership shall be allocated in the ratio that such aggregate was allocated.
Appears in 1 contract
Allocation to Reverse Deemed Capital Contributions. Any items of loss or deduction resulting from or relating to the grant of options to acquire stock, or the issuance of stock, by EnLink MidstreamCrosstex Energy, Inc., or from the transfer of any other property by the General Partner Partner, Crosstex GP, or EnLink MidstreamCrosstex Energy, Inc., to or for the benefit of any employee or other service provider of the Partnership, the Operating Partnership, or any of their respective Subsidiaries shall be specially allocated to the General Partner if and to the extent such grant of options, issuance of stock, or transfer of property was treated under applicable tax law as an actual or a deemed capital contribution by the General Partner which resulted in an increase to the General Partner’s 's Capital Account. The items of income, gain, loss and deduction that are included in an aggregate that is allocated pursuant to a provision of this Section 6.1(d) for a taxable period of the Partnership shall be allocated in the ratio that such aggregate was allocated.
Appears in 1 contract
Samples: Senior Subordinated Series B Unit Purchase Agreement (Crosstex Energy Lp)