Common use of Allocations for United States Tax Purposes Clause in Contracts

Allocations for United States Tax Purposes. ‌ If applicable, for United States federal income tax purposes, allocations of Net Income, Taxable Income, Net Loss and Taxable Loss for each Fiscal Year or other relevant period of the Partnership shall be allocated among the Partners as set out in Sections 6.1 and 6.2 except to the extent: (i) that any such allocations would not have substantial economic effect or are not in accordance with the interests of the Limited Partners in the Partnership (in each case, as determined pursuant to Section 704(b) of the Code) or (ii) otherwise required by applicable law or by reason of tax elections made by the Partnership GP on behalf of the Partnership, and, in the case of either clause (i) or (ii), the Partnership GP shall adjust allocations as necessary so as to comply with the requirements of Sections 704(b) and 704(c) of the Code and the regulations promulgated thereunder, relevant provisions of law or elections made by the Partnership GP on behalf of the Partnership (as applicable).

Appears in 2 contracts

Samples: s22.q4cdn.com, s22.q4cdn.com

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Allocations for United States Tax Purposes. If applicable, for United States federal income tax purposes, allocations of Net Income, Taxable Income, Net Loss and Taxable Loss for each Fiscal Year or other relevant period of the Partnership shall be allocated among the Partners as set out in Sections 6.1 5.1 and 6.2 5.2 except to the extent: (i) that any such allocations would not have substantial economic effect or are not in accordance with the interests of the Limited Partners in the Partnership (in each case, as determined pursuant to Section 704(b) of the Code) or (ii) otherwise required by applicable law or by reason of tax elections made by the Partnership GP on behalf of the Partnership, and, in the case of either clause (i) or (ii), the Partnership GP shall adjust allocations as necessary so as to comply with the requirements of Sections 704(b) and 704(c) of the Code and the regulations promulgated thereunder, relevant provisions of law or elections made by the Partnership GP on behalf of the Partnership (as applicable).

Appears in 1 contract

Samples: q4live.s22.clientfiles.s3-website-us-east-1.amazonaws.com

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Allocations for United States Tax Purposes. ‌ If applicable, for United States federal income tax purposes, allocations of Net Income, Taxable Income, Net Loss and Taxable Loss for each Fiscal Year or other relevant period of the Partnership shall be allocated among the Partners as set out in Sections 6.1 5.1 and 6.2 5.2 except to the extent: (i) that any such allocations would not have substantial economic effect or are not in accordance with the interests of the Limited Partners in the Partnership (in each case, as determined pursuant to Section 704(b) of the Code) or (ii) otherwise required by applicable law or by reason of tax elections made by the Partnership GP on behalf of the Partnership, and, in the case of either clause (i) or (ii), the Partnership GP shall adjust allocations as necessary so as to comply with the requirements of Sections 704(b) and 704(c) of the Code and the regulations promulgated thereunder, relevant provisions of law or elections made by the Partnership GP on behalf of the Partnership (as applicable).

Appears in 1 contract

Samples: q4live.s22.clientfiles.s3-website-us-east-1.amazonaws.com

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