Allocations and Distributions to Members. In compliance with the Treasury Regulations promulgated under applicable provisions of the Code, the Directors shall (i) allocate items of taxable income, gain, loss and deduction with respect to each Member; provided that, except as may otherwise be specifically provided in the Treasury Regulations, in all cases allocations of specific types of income shall be proportionate to the Units of the Members in a particular class thereof, and (ii) upon liquidation of the Units of a Member, make final distribution of the net assets of such a particular Member in accordance with such Member's respective Capital Account. The Directors shall provide each Member that is a regulated investment company, as defined in Section 851(a) of the Code, information that will enable it to take into account its share of items of taxable income, gain, loss and deduction as they are taken into account by the Company in order to facilitate compliance with Code Section 4982. Any income tax withholding or other withholding of taxes required by law with respect to the allocable share of income of, or distributions to, a Member shall be accounted for as a distribution to and charged to the Capital Account of such Member at the time of payment of such taxes to the applicable taxing authority.
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Samples: Limited Liability Company Agreement (Oppenheimer Master Event-Linked Bond Fund, LLC), Limited Liability Company Agreement (Oppenheimer Master International Value Fund, LLC)
Allocations and Distributions to Members. In compliance with the Treasury Regulations promulgated under applicable provisions of the Code, the Directors shall (i) allocate items of taxable income, gain, loss and deduction with respect to each Member; provided that, except as may otherwise be specifically provided in the Treasury Regulations, in all cases allocations of specific types of income shall be proportionate to the Units of the Members in a particular class thereof, and (ii) upon liquidation of the Units of a Member, make final distribution of the net assets of such a particular Member in accordance with such Member's ’s respective Capital Account. The Directors shall provide each Member that is a regulated investment company, as defined in Section 851(a) of the Code, information that will enable it to take into account its share of items of taxable income, gain, loss and deduction as they are taken into account by the Company in order to facilitate compliance with Code Section 4982. Any income tax withholding or other withholding of taxes required by law with respect to the allocable share of income of, or distributions to, a Member shall be accounted for as a distribution to and charged to the Capital Account of such Member at the time of payment of such taxes to the applicable taxing authority.
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Samples: Limited Liability Company Agreement (Oppenheimer Master Inflation Protected Securities Fund, LLC)
Allocations and Distributions to Members. In compliance with the Treasury Regulations promulgated under applicable provisions of the Code, the Directors shall (i) allocate items of taxable income, gain, loss and deduction with respect to each Member; provided that, except as may otherwise be specifically provided in the Treasury Regulations, in all cases allocations of specific types of income shall be proportionate to the Units of the Members in a particular class thereof, and (ii) upon liquidation of the Units of a Member, make final distribution of the net assets of such a particular Member in accordance with such Member's respective Capital AccountAccounts. The Directors shall provide each Member that is a regulated investment company, as defined in Section 851(a) of the Code, information that will enable it to take into account its share of items of taxable income, gain, loss and deduction as they are taken into account by the Company in order to facilitate compliance with Code Section 4982. Any income tax withholding or other withholding of taxes required by law with respect to the allocable share of income of, or distributions to, a Member shall be accounted for as a distribution to and charged to the Capital Account of such Member at the time of payment of such taxes to the applicable taxing authority.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Oppenheimer Master Loan Fund, LLC)