Common use of Allocations Relating to Taxable Issuance of Company Interests Clause in Contracts

Allocations Relating to Taxable Issuance of Company Interests. Any income, gain, loss, or deduction realized as a direct or indirect result of the issuance of an Interest by the Company to a Member (the “issuance items”) shall be allocated among the Members so that, to the extent possible, the net amount of such issuance items, together with all other allocations under the Agreement to the Members, shall be equal to the net amount that would have been allocated to the Members if the issuance items had not been realized.

Appears in 3 contracts

Samples: Limited Liability Company Operating Agreement (Diamond Resorts Parent, LLC), Limited Liability Company Agreement (Diamond Resorts Parent, LLC), Limited Liability Company Operating Agreement (Diamond Resorts Parent, LLC)

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Allocations Relating to Taxable Issuance of Company Interests. Any income, gain, loss, loss or deduction realized as a direct or indirect result of the issuance of an Interest by the Company to a Member other than pursuant to Code Section 707(a)(2) (the “issuance itemsIssuance Items”) shall be allocated among the Members so that, to the extent possible, the net amount of such issuance itemsIssuance Items, together with all other allocations under the this Agreement to the Memberseach Member, shall be equal to the net amount that would have been allocated to the Members each such Member if the issuance items Issuance Items had not been realized.

Appears in 2 contracts

Samples: Agreement of Limited Liability Company (Ims Health Inc), Limited Liability Company Agreement (Ims Health Inc)

Allocations Relating to Taxable Issuance of Company Interests. Any income, gain, loss, or deduction realized as a direct or indirect result of the issuance of an Interest by interest in the Company to a Member (the “issuance itemsIssuance Items”) shall be allocated among the Members so that, to the extent possible, the net amount of such issuance itemsIssuance Items, together with all other allocations under the this Agreement to the Memberseach Member, shall be equal to the net amount that would have been allocated to the Members each such Member if the issuance items Issuance Items had not been realized.

Appears in 1 contract

Samples: Operating Agreement

Allocations Relating to Taxable Issuance of Company Interests. Any income, gain, loss, loss or deduction realized as a direct or indirect result of the issuance of an Interest interest by the Company to a Member (the “issuance itemsIssuance Items”) shall be allocated among the Members so that, to the extent possible, the net amount of such issuance itemsIssuance Items, together with all other allocations under the this Agreement to the Memberseach Member, shall be equal to the net amount that would have been allocated to the Members each such Member if the issuance items Issuance Items had not been realized.

Appears in 1 contract

Samples: Operating Agreement (Retail Opportunity Investments Corp)

Allocations Relating to Taxable Issuance of Company Interests. Any income, gain, loss, loss or deduction realized as a direct or indirect result of the issuance of an Interest Interests by the Company to a Member (the “issuance items”"Issuance Items") shall be allocated among the Members so that, to the extent possible, the net amount of such issuance itemsIssuance Items, together with all other allocations under the this Agreement to the Members, each Member shall be equal to the net amount that would have been allocated to the Members each Member if the issuance items Issuance Items had not been realized.

Appears in 1 contract

Samples: Limited Liability Company Agreement (Amerada Hess Corp)

Allocations Relating to Taxable Issuance of Company Interests. Any income, gain, loss, loss or deduction realized as a direct or indirect result of the issuance of an Interest interest by the Company to a Member (the “issuance items”"Issuance Items") shall be allocated among the Members Member so that, to the extent possible, the net amount of such issuance itemsthe Issuance Items, together with all other allocations under the Agreement to the Memberseach Member, shall be equal to the net amount that would have been allocated to the Members each Member if the issuance items Issuance Items had not been realized.

Appears in 1 contract

Samples: Operating Agreement (Excel Corp)

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Allocations Relating to Taxable Issuance of Company Interests. Any income, gain, loss, loss or deduction realized by the Company as a direct or indirect result of the issuance of an Interest by interest in the Company to a Member (the “issuance itemsIssuance Items”) shall be allocated among the Members so that, to the extent possible, the net amount of such issuance itemsIssuance Items, together with all other allocations under the this Agreement to the Memberseach Member, shall be equal to the net amount that would have been allocated to the Members each such Member if the issuance items Issuance Items had not been realized.

Appears in 1 contract

Samples: Operating Agreement (Eldorado Resorts, Inc.)

Allocations Relating to Taxable Issuance of Company Interests. Any income, gain, loss, or deduction realized as a direct or indirect result of the issuance of an Interest a Unit by the Company to a Member (the “issuance items”"Issuance Items") shall be allocated among the Members and Assignees so that, to the extent possible, the net amount of such issuance itemsIssuance Items, together with all other allocations under the Agreement hereunder to the Memberseach Member and Assignee, shall be equal to the net amount that would have been allocated to the Members each such Member and Assignee if the issuance items Issuance Items had not been realized.

Appears in 1 contract

Samples: Operating Agreement

Allocations Relating to Taxable Issuance of Company Interests. Any income, gain, loss, loss or deduction realized as a direct or indirect result of the issuance of an Interest by interest in the Company to a Member (the “issuance items”) shall be allocated among the Members so that, to the extent possible, the net amount of such issuance items, together with all other allocations under the this Agreement to the Memberseach Member, shall be equal to the net amount that would have been allocated to the Members if each such Member of the issuance items had not been be realized.

Appears in 1 contract

Samples: Limited Liability Company Agreement (Vivakor, Inc.)

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