Allocations of Profits or Losses for Tax Purposes Sample Clauses

Allocations of Profits or 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 as follows: such Profits for Tax Purposes shall be allocated 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; such Losses shall be allocated ninety-nine percent (99%) to the class comprised of the Investor Limited Partners, and one percent (1%) to the class comprised of the General Partners.
Sample 1
AutoNDA by SimpleDocs
Allocations of Profits or Losses for Tax Purposes. (a) OPERATING PROFITS OR LOSSES. Prior to the initial closing of the sale of Units, the Profits or Losses for Tax Purposes of the Partnership shall be allocated to the Corporate Limited Partner and the General Partners in proportion to their respective Capital Contributions. Commencing with the date of the initial closing of the sale of Units, 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) shall be determined as of the end of such fiscal year, or portion thereof, and allocated ninety-eight percent (98%) to the class comprised of the Limited Partners, and two percent (2%) to the class comprised of the General Partners.
Sample 1
Allocations of Profits or Losses for Tax Purposes 
Sample 1

Related to Allocations of Profits or 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 Profit or Loss All Profit or Loss shall be allocated to the Member.

  • Allocation of Profits Profits for any Year shall be allocated in the following order and priority:

  • Allocations of Profit and Loss Whenever a proportionate part of the Company’s Profit and Loss is allocated to the Member, every item of income, gain, loss, deduction and credit entering into the computation of such Profit or Loss applicable to the period during which such Profit or Loss was realized shall be allocated to the Member.

  • Allocations for Tax Purposes (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.

  • Allocation of Profit and Loss Article V, 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:

  • Allocations of Net Profits and Net Losses (a) After giving effect to the allocations under Sections 4.2 and 7.1(b)(v), Net Profits and Net Losses and all related items of income, gain, loss, deduction and credit for each Fiscal Period shall be allocated among the Members in such manner as shall cause the Capital Accounts of each Member to equal, as nearly as possible, (i) the amount such Member would receive if all assets on hand at the end of such year were sold for cash at the Carrying Values of such assets, all liabilities were satisfied in cash in accordance with their terms (limited in the case of Member Nonrecourse Debt and Company Nonrecourse Liabilities to the Carrying Value of the assets securing such liabilities), and any remaining or resulting cash was distributed to the Members under Section 4.4(a), minus (ii) an amount equal to such Member’s allocable share of Minimum Gain as computed immediately prior to the deemed sale described in clause (i) above in accordance with the applicable Treasury Regulations, and minus (iii) the amount any such Member is treated as obligated to contribute to the Company, computed immediately after the deemed sale described in clause (i) above.

  • 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.

  • Net Losses After giving effect to the special allocations set forth in Section 6.1(d), Net Losses for each taxable period and all items of income, gain, loss and deduction taken into account in computing Net Losses for such taxable period shall be allocated as follows:

Time is Money Join Law Insider Premium to draft better contracts faster.