Allocations of Profits and Losses for Tax Purposes Sample Clauses

Allocations of Profits and Losses for Tax Purposes. For federal income tax purposes, all items of income, gain, loss, deduction or credit for any year shall be allocated in accordance with the manner in which such items of income, gain, deduction or loss affected the amounts which were either credited or charged to the capital account of the Sole Member during such year.
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Allocations of Profits and Losses for Tax Purposes. (a) For U.S. federal income tax purposes, except as otherwise provided in this Section 6.3, each item of income, gain, loss, deduction and credit of a Fund shall be allocated among the Shareholders in accordance with their respective Percentage Interests. (b) In an attempt to eliminate Book-Tax Disparities attributable to Adjusted Property, items of income, gain, or loss shall be allocated for U.S. federal income tax purposes among the Shareholders under the principles of the remedial method of Treasury Regulations section 1.704-3(d). (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 income and gain shall be specially allocated to such Shareholder in an amount and manner consistent with the allocations of income and gain pursuant to Section 6.2(c).
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Allocations of Profits and Losses for Tax Purposes. (a) Operating Profits or Losses. Prior to the admission of any Investor Limited Partner, the Profits or Losses for Tax Purposes of the Partnership shall be allocated to the Original Limited Partner and the General Partners in proportion to their respective Capital Contributions. Commencing with the first day of the month in which the initial admission of an Investor Limited Partner occurs, the Profits or Losses for Tax Purposes of the Partnership, other than Profits or Losses of the Partnership arising from a Capital Transaction and the Terminating Capital Transaction, for each fiscal year (or portion thereof in the case of the initial fiscal year in which any Investor Limited Partner shall be admitted) shall be determined as of the end of such fiscal year, or portion thereof, and allocated among the classes comprised of the Investor Limited Partners, the Original Limited Partner, and the General Partners in the same proportions as distributions of Cash Flow are made pursuant to Section 8.2(b) hereof, or, in the event no Cash Flow is then available for distribution, in the respective proportions in which Cash Flow would have been distributed under that Section if then available in the amount of such Profits or Losses.
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Allocations of Profits and Losses for Tax Purposes a. After giving effect to the special allocations provided in Section 6.5, and except as otherwise provided in Section 6.4(c), Profits for any Fiscal Year or Accounting Period shall be allocated to the Members as follows: (1) First, to each Member in an amount equal to the excess, if any, of (i) the cumulative Losses allocated to such Member pursuant to Section 6.4(b) for all prior Fiscal Years and prior Accounting Periods in the current Fiscal Year over (ii) the cumulative Profits allocated to such Member pursuant to this Section 6.4(a) for all such prior Fiscal Years and Accounting Periods; provided that, if the Profits of the current Fiscal Year or Accounting Period are less than the sum of such excess for all Members, such Profits shall be allocated to each Member in proportion to its share of such sum; and (2) Second, to the Members in proportion to their respective Membership Points as of the end of that Fiscal Year or Accounting Period, as the case may be. b. After giving effect to the special allocations provided in Section 6.5, and except as otherwise provided in Section 6.4(c), Losses for any Fiscal Year or Accounting Period shall be allocated to the Members as follows: (1) First, to each Member in an amount equal to the excess, if any, of (i) the cumulative Profits allocated to such Member pursuant to Section 6.4(a) for all prior Fiscal Years and prior Accounting Periods in the current Fiscal Year over (ii) the cumulative Losses allocated to such Member pursuant to this Section 6.4(b) for all such prior Fiscal Years and Accounting Periods; provided that, if the Losses of the current Fiscal Year or Accounting Period are less than the sum of such excess for all Members, such Losses shall be allocated to each Member in proportion to its share of such sum, and provided further that no current Fiscal Year Losses shall be allocated to any Member to the extent such allocation would cause such Member to have a deficit in its Capital Account; (2) Second, to the Members in proportion to their respective Membership Points as of the end of that Fiscal Year or Accounting Period, as the case may be, up to the amount of their positive Capital Account balances as of that time; and (3) Third, to the Members in proportion to their respective Capital Account balances as of the end of that Fiscal Year or Accounting Period, as the case may be. c. Notwithstanding Section 6.4(a), Profits and Losses from the sale of all or substantially all of the LLC's assets, and Pro...
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Allocations of Profits and Losses for Tax Purposes. For federal tax purposes, in accordance with Section 704(c) of the Code and any regulations thereunder, gain with respect to any property which may be contributed to the Company shall, solely for tax purposes, be allocated among the Members so as to take account of any variation between the adjusted tax basis of such property to the Company and the fair market value at the time of contribution.
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Allocations of Profits and Losses for Tax Purposes. The following allocations are solely, for tax purposes, and shall not affect the Members’ Capital Accounts: A. For federal tax purposes, in accordance with Section 704(c) of the Code, gain with respect to any property which may be contributed shall, solely for tax purposes, be allocated among the Members so as to take account of any variation between the adjusted tax basis of such property to the Company and the fair market value at the time of contribution in accordance with Section 704(c) of the Code. Any difference between the Book Value and tax basis of any property resulting from a revaluation pursuant to Section 4.7 above shall also be taken into account under the principles of Section 704(c) of the Code and the regulations thereunder using the so-called “traditional method” of Section 1.704-3(b) of the Regulations unless the Members otherwise expressly agree.
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Allocations of Profits and Losses for Tax Purposes. The following allocations are solely for tax purposes, and shall not affect the Members’ Capital Accounts: (a) For federal tax purposes, in accordance with Section 704(c) of the Code, gain or loss and any depreciation, amortization or other cost recovery with respect to any property which may be contributed shall, solely for tax purposes, be allocated among the Members so as to take account of any variation between the adjusted tax basis of such property to the Company and the fair market value at the time of contribution in accordance with Section 704(c) of the Code. Any difference between the Book Value and tax basis of any property resulting from a revaluation described in the definition of Book Value in Section 1.1 above (or from the adjustments to the Book Values of the Company’s assets described in the third sentence of Section 8.9) shall also be taken into account under the principles of Section 704(c) of the Code and the regulations thereunder using the so-called “traditional method” of Section 1.704-3(b) of the Regulations without any curative or remedial allocations unless the Members otherwise expressly agree.
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Allocations of Profits and Losses for Tax Purposes. For federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Members in the same manner as its correlative item of "book" income, gain, loss or deduction is allocated pursuant to this Agreement. In an attempt to eliminate Book-Tax Disparities attributable to a Contributed Property, items of income, gain, loss and deduction attributable to a Contributed Property shall be allocated for federal income tax purposes among the Members as follows: (a) In the case of a Contributed Property, such items attributable thereto shall be allocated among the Members consistent with the principles of Section 704(c) of the Code to take into account the variation between the 704(c) Value of such property and its adjusted basis at the time of contribution; and (b) any gain or loss remaining attributable to a Contributed Property shall be allocated among the Members in the same manner as its correlative items of "book" gain or loss is allocated pursuant to this Agreement. To the extent the Regulations promulgated pursuant to Section 704(c) of the Code permit the utilization of alternative methods to eliminate the disparity between the agreed value of property and its adjusted basis, the Managing Member shall have the authority to elect the method to be used by the Company, and such election shall be binding on all Members.
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Allocations of Profits and Losses for Tax Purposes. (a) For Federal tax purposes, except insofar as adjustments pursuant to Section 704(c) principles may be permitted or required by Treasury Regulation Section 1.704-l(b)(2)(iv) by reason of property being contributed to the Company, as required by Treasury Regulations Section 1.704-l(b)(2)(iv)(d), property being distributed by the Company as required by Section 1.704-l(b)(2)(iv)(c), property being revalued by the Company (a “book-up”) as permitted by Treasury Regulations Section 7.704-l(b)(2)(iv)(f) or a Company interest being transferred, and subject to and consistent with Sections 734 and 743 of the Code, each item of income, gain, loss and deduction of the Company shall be allocated among the Members in the same manner as its correlative item of “book” income, gain, loss or deduction has been allocated pursuant to Section 9.4. (b) A Majority-in-Interest of Members shall have the authority to elect the method to be used by the Company for allocating items of income, gain, and expense as required by Section 704(c) of the Code, and such election shall be binding on all Members. For federal tax purposes, in accordance with Section 704(c) of the Code and any regulations thereunder, gain with respect to any property which may be contributed to the Company shall, solely for tax purposes, be allocated among the Members so as to take account of any variation between the adjusted tax basis of such property to the Company and the fair market value at the time of contribution. The Members acknowledge that all allocations of items of income, gain, and expenses as required by Section 704(c) of the Code associated with the property and other properties that may be contributed to the Company by Extra Space or an Affiliate in the future will be made in accordance with the “traditional method” as set forth in Regulations Section 1.704-3(b).
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Related to Allocations of Profits and Losses for Tax Purposes

  • Allocations of Profits and Losses Except as otherwise provided in this Agreement, Profits and Losses (and, to the extent necessary, individual items of income, gain or loss or deduction of the Partnership) shall be allocated in a manner such that the Capital Account of each Partner after giving effect to the Special Allocations set forth in Section 5.05 is, as nearly as possible, equal (proportionately) to (i) the distributions that would be made pursuant to Article IV if the Partnership were dissolved, its affairs wound up and its assets sold for cash equal to their Carrying Value, all Partnership liabilities were satisfied (limited with respect to each non-recourse liability to the Carrying Value of the assets securing such liability) and the net assets of the Partnership were distributed to the Partners pursuant to this Agreement, minus (ii) such Partner’s share of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain, computed immediately prior to the hypothetical sale of assets. For purposes of this Article V, each Unvested Unit shall be treated as a Vested Unit. Notwithstanding the foregoing, the General Partner shall make such adjustments to Capital Accounts as it determines in its sole discretion to be appropriate to ensure allocations are made in accordance with a partner’s interest in the Partnership.

  • Allocation of Profits and Losses The Company’s profits and losses shall be allocated to the Member.

  • Allocation of Profits and Losses Distributions Profits/Losses. For financial accounting and tax purposes, the Company's net profits or net losses shall be determined on an annual basis and shall be allocated to the Members in proportion to each Member's relative capital interest in the Company as set forth in Schedule 2 as amended from time to time in accordance with U.S. Department of the Treasury Regulation 1.704-1.

  • Allocations of Net Profits and Net Losses Except as otherwise set forth herein, Net Profits and Net Losses shall be allocated for each Fiscal Year to the Members in proportion to their respective Capital Accounts.

  • Allocations of Net Income and Net Loss Except as otherwise provided in this Agreement, after giving effect to the special allocations in subparagraph 1(c) and paragraph 2, Net Income, Net Loss and, to the extent necessary, individual items of income, gain, loss or deduction, of the Partnership for each fiscal year or other applicable period of the Partnership shall be allocated among the General Partner and Limited Partners in accordance with their respective Percentage Interests.

  • Allocation of Profits Profits for any Year shall be allocated in the following order and priority: (i) First, to any Partner who was allocated Losses after the Capital Account of any other Partner was reduced to zero (0), to the extent of such Losses; provided, however, that in the event that the foregoing applies to more than one Partner, to those Partners pro rata according to the amount of such Losses allocated to each; and (ii) Second, to the Partners in accordance with their relative Percentage Interests.

  • Allocation of Profit and Loss Section 5.01 of the Partnership Agreement is hereby deleted in its entirety and the following new Section 5.01 is inserted in its place:

  • Allocation of Profit or Loss All Profit or Loss shall be allocated to the Member.

  • Allocation of Net Profits and Net Losses As of the last day of each Fiscal Period, any Net Profits or Net Losses for the Fiscal Period shall be allocated among and credited to or debited against the Capital Accounts of the Members in accordance with their respective Investment Percentages for such Fiscal Period.

  • Profits and Losses For financial accounting and tax purposes, the Company’s net profits or net losses shall be determined on an annual basis in accordance with the manner determined by the Board. In each year, profits and losses shall be allocated entirely to the Member.

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