Allocations of Income and Losses. All items of income or loss of the Partnership shall be allocated to the Partners in accordance with the provisions of Exhibit A attached hereto, which is hereby incorporated by reference for all purposes of this Agreement.
Allocations of Income and Losses. All items of income or loss of the Company shall be allocated to the Members accordance with the provisions of Exhibit A attached hereto, which is hereby incorporated by reference for all purposes of this Agreement or as otherwise provided in Ws Agreement.
Allocations of Income and Losses. (a) Income for each fiscal year or part thereof of the Company shall be allocated to the Members as follows:
(i) If there is a disposition described in Section 5.2(a) whether directly or by application of Section 5.2(c) during such fiscal year or part thereof, Income from such disposition shall be allocated as follows:
Allocations of Income and Losses. (a) Income for each fiscal year or part thereof of the Company shall be allocated to the Members as follows:
(i) If there is a disposition described in Section 5.2(a) whether directly or by application of Section 5.2(c) during such fiscal year or part thereof, Income from such disposition shall be allocated as follows:
(A) First to the Class A Member to the extent the amount of the Adjusted Unreturned Class A Member's Capital Contribution distributed to the Class A Member under Section 5.2(a)(i) for such year from such disposition would otherwise exceed the positive Capital Account balance of the Class A Member (after taking into account the distribution);
(B) Next to the Class A Member to the extent that the amount distributed to the Class A Member under Section 5.2(a)(ii) for such year from such disposition would otherwise exceed the positive Capital Account balance of the Class A Member (after taking into account the distribution), taking into account the allocation provided for in Section 5.1(a)(i)(A);
(C) Next 55% to the Class B Member and 45% to the Class A Members as a group until the Class B Members have been allocated Income under this Section 5.1(a)(i)(C) equal to the aggregate amounts distributed to the Class B Members under Sections 5.2(a)(iii) (whether directly or by application of Section 5.2(c)); and
(D) The balance to the Class A Member and the Class B Members as a group in proportion to their respective Adjusted Percentage Interests of the Class A Member and the Class B Members as a group as of the date of the disposition.
(ii) If there is a disposition described in Section 5.2(b) during such fiscal year or part thereof, Income from such disposition shall be allocated as follows:
(A) First to the Class A Member to the extent the amount distributed to the Class A Member under Section 5.2(b)(i) for such year from all such dispositions would otherwise exceed the positive Capital Account balance of the Class A Member;
(B) Next to the Class A Member to the extent that the amount distributed to the Class A Member under Section 5.2(b)(ii) for such year from all such dispositions would otherwise exceed the positive Capital Account balance of the Class A Member, taking into account the allocation provided for in Section 5.1(a)(ii)(A);
(C) The balance to the Class A Member. Notwithstanding the foregoing provisions (A), (B) and (C) of this Section 5.1(a)(ii), if any distribution from such disposition is made to the Class B Members as a group under Se...
Allocations of Income and Losses. All items of income, gain, loss and deductions shall be allocated to the Certificateholders' Capital Accounts in a manner consistent with the distribution procedures set forth in Article V; PROVIDED, HOWEVER, that any loss resulting from a default on a Purchased Contract Receivable shall be allocated to the Residual Certificateholder; and PROVIDED, FURTHER, that if the losses resulting from a default on one or more Purchased Contract Receivables would exceed the current balance of the Residual Certificateholder's Capital Account, then an amount of such losses equal to the current balance of the Residual Certificateholder's Capital Account shall be allocated to the Residual Certificateholder and any excess losses shall be allocated to the Investor Certificateholders on a pro rata basis in accordance with the balances in their Capital Accounts.
Allocations of Income and Losses. Income and Losses shall be allocated to the Partners for each period described below, as follows:
Allocations of Income and Losses. So long as the Company has only one member, all items of income, gain, loss, expense, deduction and credit shall be allocated to the Member.
Allocations of Income and Losses. All items of income, gain, loss and deduction of Local Insight for taxable year which includes the Closing Date shall be allocated between the holders of membership interests in Local Insight immediately prior to the Closing Date (the “Existing Members”) and the Contributors based on a closing of the books of Local Insight on the Closing Date, and as a result, all items of income, gain, loss or deduction of Local Insight which arise in any taxable period or portion thereof that ends on or prior to the Closing Date shall be allocated solely to the Exiting Members.
Allocations of Income and Losses. (a) The net income and net losses of the Partnership for each fiscal year shall be determined in accordance with generally accepted accounting principles, as varied by appropriate regulatory authorities. Such net income and net losses shall be allocated to the Partners in proportion to their respective Partnership Interests.
(b) For income tax purposes, the taxable income or loss of the Partnership for any fiscal year (and each item of income, gain, loss, deduction and credit) shall be allocated to the Partners in proportion to their respective Partnership Interests, as adjusted pursuant to Section 706(d) of the Internal Revenue Code, if applicable. Except as otherwise provided in this Agreement, whenever a proportionate part of the Partnership’s taxable income or losses is credited or charged to a Partner’s capital account, every item of income, gain, loss or deduction entering into the computation of such taxable income or losses shall be considered credited or charged, as the case may be, and every item of credit or tax preference applicable to the period during which such taxable income or losses was realized shall be allocated, but not credited or charged, to such account in the same proportion.
(c) If at the time any property is contributed to the Partnership, the Partner’s adjusted basis for Federal income tax purposes for such property differs from its fair market value (as credited to such Partner’s capital account pursuant to Section 6.1, the items of income, gain, loss, deduction and expense with respect to such contributed property for each year shall be allocated to the Partners pursuant to Section 704(c) of the Internal Revenue Code in a manner that takes into account that difference between adjusted basis and fair market value. The capital accounts of the Partners shall not be adjusted by reason of amounts allocated to the Partners pursuant to the preceding sentence. For purposes of adjusting the capital accounts of the Partners, the items of income, gain, loss, deduction and expense with respect to such contributed property for each year shall be computed as if each Partner’s adjusted basis for Federal income tax purposes in the property contributed to the Partnership equaled its fair market value, and the capital account of each Partner shall be credited or charged, as the case may be, with the percentage of each such item as so computed which equals the Partnership Interest of such Partner. To the extent not inconsistent with the provisio...
Allocations of Income and Losses. Income and Losses for each calendar year, or fraction thereof, as the case may be, shall be allocated to the Members (and for purposes of this Article 6, the term "Member" shall include Investors and any holder of Shares whether or not such holder has been admitted to membership in the Fund) as follows:
