Common use of Allocations for Capital Account Purposes Clause in Contracts

Allocations for Capital Account Purposes. (a) For purposes of maintaining Capital Accounts and in determining the rights of the Shareholders among themselves, except as otherwise provided in this Section 6.2 each item of income, gain, loss, expense and deduction (computed in accordance with Section 6.1(b)) shall be allocated to the Shareholders in accordance with their respective Percentage Interests. (b) Pursuant to Treasury Regulations section 1.704-1(b)(2)(iv)(g), items of depreciation, depletion, amortization and gain or loss attributable to Adjusted Property that has a Book-Tax Disparity shall be allocated among the Shareholders in accordance with Treasury Regulations section 1.704-1(b)(2)(iv)(g)(3). (c) If any Shareholder unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulations section 1.704-1(b)(2)(ii)(d), items of the Fund’s income and gain shall be specially allocated to such Shareholder in an amount and manner sufficient to eliminate a deficit balance in its Capital Account (after decreasing such Shareholder’s Capital Account balance by the items described in Treasury Regulations section 1.704-1(b)(2)(ii)(d)) created by such adjustments, allocations or distributions as quickly as possible. This Section 6.2(c) is intended to constitute a “qualified income offset” within the meaning of Treasury Regulations section 1.704-1(b)(2)(ii)(d).

Allocations for Capital Account Purposes. (a) For purposes of maintaining Capital Accounts and in determining the rights of the Shareholders Unitholders among themselves, except as otherwise provided in this Section 6.2 7.2 each item of income, gain, loss, expense and deduction (computed in accordance with Section 6.1(b7.1(b)) shall be allocated to the Shareholders Unitholders in accordance with their respective Percentage Interests. (b) Pursuant to Treasury Regulations section 1.704-1(b)(2)(iv)(g), items of depreciation, depletion, amortization and gain or loss attributable to Adjusted Property that has a Book-Tax Disparity shall be allocated among the Shareholders Unitholders in accordance with Treasury Regulations section 1.704-1(b)(2)(iv)(g)(3). (c) If any Shareholder Unitholder unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulations section 1.704-1(b)(2)(ii)(d1(b)(2)(ii)(d)(5) or 1.704- 1(b)(2)(ii)(d)(6), items of the a Fund’s income and gain shall be specially allocated to such Shareholder Unitholder in an amount and manner sufficient to eliminate a deficit balance in its Capital Account (after decreasing such ShareholderUnitholder’s Capital Account balance by the items described in Treasury Regulations section 1.704-1(b)(2)(ii)(d1(b)(2)(ii)(d)(5) and 1.704-1(b)(2)(ii)(d)(6)) created by such adjustments, allocations or distributions as quickly as possible. This Section 6.2(c7.2(c) is intended to constitute a “qualified income offset” within the meaning of Treasury Regulations section 1.704-1(b)(2)(ii)(d).

Allocations for Capital Account Purposes. (a) For purposes of maintaining Capital Accounts and in determining the rights of the Shareholders Unitholders among themselves, except as otherwise provided in this Section 6.2 7.2 each item of income, gain, loss, expense and deduction (computed in accordance with Section 6.1(b7.1(b)) shall be allocated to the Shareholders Unitholders in accordance with their respective Percentage Interests. (b) Pursuant to Treasury Regulations section 1.704-1(b)(2)(iv)(g), items of depreciation, depletion, amortization and gain or loss attributable to Adjusted Property that has a Book-Tax Disparity shall be allocated among the Shareholders Unitholders in accordance with Treasury Regulations section 1.704-1(b)(2)(iv)(g)(3). (c) If any Shareholder Unitholder unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulations section 1.704-1(b)(2)(ii)(d1(b)(2)(ii)(d)(5) or 1.704-1(b)(2)(ii)(d)(6), items of the a Fund’s income and gain shall be specially allocated to such Shareholder Unitholder in an amount and manner sufficient to eliminate a deficit balance in its Capital Account (after decreasing such ShareholderUnitholder’s Capital Account balance by the items described in Treasury Regulations section 1.704-1(b)(2)(ii)(d1(b)(2)(ii)(d)(5) and 1.704-1(b)(2)(ii)(d)(6)) created by such adjustments, allocations or distributions as quickly as possible. This Section 6.2(c7.2(c) is intended to constitute a “qualified income offset” within the meaning of Treasury Regulations section 1.704-1(b)(2)(ii)(d).

Allocations for Capital Account Purposes. (a) For purposes of maintaining Capital Accounts and in determining the rights of the Shareholders Unitholders among themselves, except as otherwise provided in this Section 6.2 7.2 each item of income, gain, loss, expense and deduction (computed in accordance with Section 6.1(b7.1(b)) shall be allocated to the Shareholders Unitholders in accordance with their respective Percentage Interests. (b) Pursuant to Treasury Regulations section 1.704-1(b)(2)(iv)(g), items of depreciation, depletion, amortization and gain or loss attributable to Adjusted Property that has a Book-Tax Disparity shall be allocated among the Shareholders Unitholders in accordance with Treasury Regulations section 1.704-1(b)(2)(iv)(g)(3). (c) If any Shareholder unitholder unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulations section 1.704-1(b)(2)(ii)(d1(b)(2)(ii)(d)(5) or 1.704-1(b)(2)(ii)(d)(6), items of the a Fund’s income and gain shall be specially allocated to such Shareholder unitholder in an amount and manner sufficient to eliminate a deficit balance in its Capital Account (after decreasing such Shareholderunitholder’s Capital Account balance by the items described in Treasury Regulations section 1.704-1(b)(2)(ii)(d1(b)(2)(ii)(d)(5) and 1.704-1(b)(2)(ii)(d)(6)) created by such adjustments, allocations or distributions as quickly as possible. This Section 6.2(c7.2(c) is intended to constitute a “qualified income offset” within the meaning of Treasury Regulations section 1.704-1(b)(2)(ii)(d).

Allocations for Capital Account Purposes. (a) For purposes of maintaining Capital Accounts and in determining the rights of the Shareholders Unitholders among themselves, except as otherwise provided in this Section 6.2 7.2 each item of income, gain, loss, expense and deduction (computed in accordance with Section 6.1(b7.1(b)) shall be allocated to the Shareholders Unitholders in accordance with their respective Percentage Interests. (b) Pursuant to Treasury Regulations section 1.704-1(b)(2)(iv)(g), items of depreciation, depletion, amortization and gain or loss attributable to Adjusted Property that has a Book-Tax Disparity shall be allocated among the Shareholders Unitholders in accordance with Treasury Regulations section 1.704-1(b)(2)(iv)(g)(3). (c) If any Shareholder Unitholder unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulations section 1.704-1(b)(2)(ii)(d1(b)(2)(ii)(d)(5) or 1.704-1(b)(2)(ii)(d)(6), items of the a Fund’s income and gain shall be specially allocated to such Shareholder Unitholder in an amount and manner sufficient to eliminate a deficit balance in its Capital Account (after decreasing such ShareholderUnitholder’s Capital Account balance by the items described in Treasury Regulations section 1.704-1(b)(2)(ii)(d1(b) (2)(ii)(d)(5) and 1.704-1(b)(2)(ii)(d)(6)) created by such adjustments, allocations or distributions as quickly as possible. This Section 6.2(c7.2(c) is intended to constitute a “qualified income offset” within the meaning of Treasury Regulations section 1.704-1(b)(2)(ii)(d).

Allocations for Capital Account Purposes. (a) For purposes of maintaining Capital Accounts and in determining the rights of the Shareholders among themselves, except as otherwise provided in this Section 6.2 each item of income, gain, loss, expense and deduction (computed in accordance with Section 6.1(b)) shall be allocated to the Shareholders in accordance with their respective Percentage Interests. (b) Pursuant to Treasury Regulations section 1.704-1(b)(2)(iv)(g), items of depreciation, depletion, amortization and gain or loss attributable to Adjusted Property that has a Book-Tax Disparity shall be allocated among the Shareholders in accordance with Treasury Regulations section 1.704-1(b)(2)(iv)(g)(3). (c) If any Shareholder unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulations section 1.704-1(b)(2)(ii)(d1(b)(2)(ii)(d)(5) or 1.704- 1(b)(2)(ii)(d)(6), items of the Fund’s income and gain shall be specially allocated to such Shareholder in an amount and manner sufficient to eliminate a deficit balance in its Capital Account (after decreasing such Shareholder’s Capital Account balance by the items described in Treasury Regulations section 1.704-1(b)(2)(ii)(d1(b)(2)(ii)(d)(5) and 1.704-1(b)(2)(ii)(d)(6)) created by such adjustments, allocations or distributions as quickly as possible. This Section 6.2(c) is intended to constitute a “qualified income offset” within the meaning of Treasury Regulations section 1.704-1(b)(2)(ii)(d).

Allocations for Capital Account Purposes. (a) For purposes of maintaining Capital Accounts and in determining the rights of the Shareholders among themselves, except as otherwise provided in this Section 6.2 each item of income, gain, loss, expense and deduction (computed in accordance with Section 6.1(b)) shall be allocated to the Shareholders in accordance with their respective Percentage Interests.. 32 (b) Pursuant to Treasury Regulations section 1.704-1(b)(2)(iv)(g), items of depreciation, depletion, amortization and gain or loss attributable to Adjusted Property that has a Book-Tax Disparity shall be allocated among the Shareholders in accordance with Treasury Regulations section 1.704-1(b)(2)(iv)(g)(3). (c) If any Shareholder unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulations section 1.704-1(b)(2)(ii)(d), items of the Fund’s income and gain shall be specially allocated to such Shareholder in an amount and manner sufficient to eliminate a deficit balance in its Capital Account (after decreasing such Shareholder’s Capital Account balance by the items described in Treasury Regulations section 1.704-1(b)(2)(ii)(d)) created by such adjustments, allocations or distributions as quickly as possible. This Section 6.2(c) is intended to constitute a “qualified income offset” within the meaning of Treasury Regulations section 1.704-1(b)(2)(ii)(d).