Allocations on Transfers Sample Clauses
Allocations on Transfers. In the event of an assignment of a Partner’s interest in the Partnership pursuant to Article VIII, deductions, credits, and income of the Partnership for federal, state, and local income tax purposes shall, unless otherwise required by applicable Treasury Regulations, be allocated between the assignor and assignee based on the number of days of the year during which each party owned such interest.
Allocations on Transfers. Taxable items of the Company attributable to a Membership Interest that has been transferred (including the simultaneous decrease in the Membership Interest of existing Members resulting from the admission of a new Member) shall be allocated between the transferor and the transferee using the proration method in accordance with Treasury Regulations Section 1.706-4. Notwithstanding the foregoing, the Company may, at the discretion of the Managers, make an interim closing of its books as of the date that a Membership Interest has been transferred (including the simultaneous decrease in Membership Interest of existing Members resulting from the admission of a new Member), and allocate taxable items of the Company attributable to such Membership Interest based on such interim closing in accordance with Treasury Regulations Section 1.706-4. Distributions of assets of the Company with respect to a Membership Interest shall be made only to the Persons who, according to the records of the Company, are the owners, on the actual date of distribution, of the Membership Interests with respect to which the distributions are made. No liability shall result from making distributions in accordance with the provisions of the preceding sentence, whether or not any Manager or the Company has knowledge or notice of a transfer or purported transfer of ownership of a Membership Interest.
Allocations on Transfers. If any Interest is transferred during any Allocation Year in compliance with the provisions of the Agreement, Profits, Losses, each item thereof, and all other items attributable to the transferred Interest for such Allocation Year shall be divided and allocated between the transferor and the transferee by taking into account their varying interests during such Allocation Year in accordance with Section 706(d) of the Code, using any methods and conventions permitted by Treasury Regulations Section 1.706-4 that is selected by the General Partner. Solely for purposes of making such allocations, the Partnership shall recognize such Transfer as of time that such Transfer is deemed to occur under Treasury Regulations Section 1.706-4, even if such Transfer is deemed to occur prior to or after the actual Transfer. Notwithstanding any provision of this Agreement to the contrary, this Section 3.5 is intended to be and shall be interpreted as an “agreement of the partners” (within the meaning of Treasury Regulations Section 1.706-4(f)) that the General Partner is authorized to select the methods, conventions, and additional extraordinary items within the meaning of Treasury Regulations Sections 1.707-4(a)(3)(iii), (c)(3), (d), and (e)(2)(ix) for purposes of determining the transferor’s and transferee’s distributive shares of the Partnership’s Profits, Losses, each item thereof, and all other items attributable to the transferred Interest.
Allocations on Transfers. Unless another method is required by the Code or if another method is permitted by the Code and is agreed to by the General Partner, the Transferor, and the Transferee, Profit and Loss, and each item thereof, attributable to any Interest that has been Transferred shall be allocated between the Transferor and Transferee in proportion to the number of days each held such Interest during the Allocation Year without regard to Partnership’s operations during such days. However, gain or loss realized on a Transfer of Property other than in the ordinary course of business shall be allocated to the Person holding such Transferred Interest on the date of such Transfer.
Allocations on Transfers. Unless otherwise agreed in writing by a transferor and transferee of a Membership Interest herein, income, gain, loss, deduction or credit attributable to any Membership Interest that has been transferred shall be allocated between the transferor and the transferee using an acceptable method as provided under section 706 of the Code and related Treasury Regulations.
Allocations on Transfers. Taxable items of the Company attributable to a Membership Interest that has been transferred (including the simultaneous decrease in the Membership Interest of existing Members resulting from the admission of a new Member) shall be allocated between the transferor and the transferee based on an interim closing of the books or such other permissive method in accordance with Code Section 706 reasonably selected by the Manager. Distributions of assets of the Company with respect to a Membership Interest shall be made only to the Persons who, according to the records of the Company, are the owners, on the actual date of distribution, of the Membership Interests with respect to which the distributions are made. No liability shall result from making distributions in accordance with the provisions of the preceding sentence, whether or not the Manager of the Company has knowledge or notice of a Transfer or purported Transfer of ownership of a Membership Interest.
Allocations on Transfers. Income, gain, loss, deduction, or credit attributable to any Partnership Units which have been transferred shall be allocated between the transferor and the transferee as follows:
(a) For the months prior to the transfer, to the transferor.
(b) For the months subsequent to the transfer, to the transferee.
(c) For the month of the transfer, to the transferee if the transfer occurs on or before the fifteenth day of such month and to the transferor if occurring thereafter. For purposes of the above allocation, income, gains, losses, and deductions shall be allocated equally among the months of the Partnership’s fiscal year without regard to Partnership operations during such months except for deductions attributable to Cash Basis Items which shall be allocated to the actual months the deduction for such Cash Basis Items would accrue if the Partnership were on the accrual method of accounting. If the use of such accrual method results in the deduction for a Cash Basis Item being allocable to a fiscal year of the Partnership preceding or following the year of transfer, said deduction shall be allocated to the first or last month of the fiscal year of the transfer, respectively.
Allocations on Transfers. Income, gain, loss, deduction, or credit attributable to an Interest that has been Transferred (including the simultaneous decrease in the Interest of existing Members resulting from the admission of a new Member) shall be allocated between the transferor and the transferee as follows: (i) for the months before the Transfer, to the transferor; (ii) for the months after the Transfer, to the transferee; and (iii) for the month of the Transfer, to the transferee if the Transfer occurs on or before the Limited Liability Company Agreement of First Cash Management, L.L.C. 5 fifteenth (15th) day of the month and to the transferor if the Transfer occurs thereafter. For purposes of the above allocation, all such items shall be allocated equally among the months of the Fiscal Year without regard to the Company’s operations during those months. Distributions of Company assets with respect to an Interest shall be made only to the Persons who, according to the records of the Company, are the owners, on the actual date of distribution, of the Interests with respect to which the distributions are made. No liability shall result from making distributions in accordance with the provisions of the preceding sentence, whether or not any Member or the Company has knowledge or notice of a Transfer or purported transfer of ownership of an Interest.