Allocations on Transfer of Interests. All items of income, gain, loss, deduction, and credit allocable to any interest in the Company that may have been transferred shall be allocated between the transferor and the transferee based upon that portion of the calendar year during which each was recognized as owning such interest, without regard to the results of Company operations during any particular portion of such calendar year and without regard to whether cash distributions were made to the transferor or the transferee during such calendar year; however, such allocation shall be made in accordance with a method permissible under section 706 of the Code and the Regulations thereunder.
Appears in 5 contracts
Samples: Limited Liability Company Agreement (DCT Chino LLC), Limited Liability Company Agreement (DCT Chino LLC), Limited Liability Company Agreement (DCT Chino LLC)
Allocations on Transfer of Interests. All items of income, gain, loss, deduction, and credit allocable to any interest in the Company that may have been transferred shall be allocated between the transferor and the transferee based upon that portion of the calendar year during which each was recognized as owning such interest, without regard to the results of Company operations during any particular portion of such calendar year and without regard to whether cash distributions were made to the transferor transferee or the transferee during such calendar year; however, such allocation shall be made in accordance with a method permissible under section 706 of the Code and the Regulations thereunder.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Storage Usa Inc), Limited Liability Company Agreement (Storage Usa Inc)
Allocations on Transfer of Interests. All items of income, gain, loss, deduction, and credit allocable to any interest in the Company that may have been transferred shall be allocated between the transferor and the transferee based upon that portion of the calendar year during which each was recognized as owning such interest, without regard to the results of Company operations during any particular portion of such calendar year and without regard to whether cash distributions were made to the transferor or the transferee during such calendar year; however, such allocation shall be made in accordance with a method permissible under section Section 706 of the Code and the Regulations thereunder, and reasonably acceptable to the Managing Member.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Hilton Grand Vacations Inc.)
Allocations on Transfer of Interests. All items of income, gain, loss, deduction, and credit allocable to any interest in the Company that may have been transferred shall be allocated between the transferor and the transferee based upon that portion of the calendar year during which each was recognized as owning such interest, without regard to the results of Company operations during any particular portion of such calendar year and without regard to whether cash distributions were made to the transferor or the transferee during such calendar year; however, such allocation shall be made in accordance with a method permissible under section Section 706 of the Code and the Treasury Regulations thereunder.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Nexcore Healthcare Capital Corp)
Allocations on Transfer of Interests. All items of income, gain, loss, deduction, and credit allocable to any interest in the Company that may have been transferred shall be allocated between the transferor and the transferee based upon that portion of the calendar year Fiscal Year during which each was recognized as owning such interest, without regard to the results of Company operations during any particular portion of such calendar year Fiscal Year and without regard to whether cash distributions were made to the transferor transferee or the transferee during such calendar yearFiscal Year; however, such allocation shall be made in accordance with a method permissible under section Section 706 of the Code and the Regulations thereunder.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Apartment Investment & Management Co)
Allocations on Transfer of Interests. All items of income, gain, loss, deduction, and credit allocable to any interest in the Company that may have been transferred shall be allocated between the transferor and the transferee based upon that portion of the calendar year during which each was recognized as owning such interest, without regard to the results of Company operations during any particular portion of such calendar year and without regard to whether cash distributions were made to the transferor transferee or the transferee during such calendar year; however, such allocation shall be made in accordance with a method permissible under section Section 706 of the Code and the Regulations thereunder.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Lightstone Real Estate Income Trust Inc.)
Allocations on Transfer of Interests. All items of income, gain, loss, deduction, and credit allocable to any interest Membership Interests in the Company that may have been transferred shall be allocated between the transferor and the transferee based upon that portion of the calendar year during which each was recognized as owning such interestMembership Interests, without regard to the results of Company operations during any particular portion of such calendar year and without regard to whether cash distributions Distributions were made to the transferor or the transferee during such calendar year; however, such allocation shall be made in accordance with a method permissible under section Section 706 of the Code and the Regulations thereunder.
Appears in 1 contract
Samples: Agreement
Allocations on Transfer of Interests. All items of income, gain, loss, deduction, and credit allocable to any interest in the Company that may have been transferred shall be allocated between the transferor and the transferee based upon that portion of the calendar year during which each was recognized as owning such interest, without regard to the results of Company operations during any particular portion of such calendar year and without regard to whether cash distributions were made to the transferor or the transferee during such calendar year; however, such allocation shall be made in accordance with a method permissible under section Section 706 of the Code and the Regulations thereunder.
Appears in 1 contract
Samples: Limited Liability Company Agreement (DCT Chino LLC)