Allocations Relating to Taxable Issuance of Interest. Any income, gain, loss or deduction realized by the Company as a direct or indirect result of the issuance of an Interest by the Company (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 this Agreement to each Member, shall be equal to the net amount that would have been allocated to each such Member if the Issuance Items had not been realized.
Appears in 6 contracts
Samples: Pledge and Security Agreement (Wellsford Residential Property Trust), Pledge and Security Agreement (Equity Residential Properties Trust), Operating Agreement (Wellsford Real Properties Inc)
Allocations Relating to Taxable Issuance of Interest. Any income, gain, loss loss, or deduction realized by the Company as a direct or indirect result of the issuance of an Interest interest in the Company 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 this Agreement to each Member, shall be equal to the net amount that would have been allocated to each such Member if the Issuance Items had not been realized.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Mysk Orlando Growth Fund LLC), Venture on Country Club, Investment Agreement
Allocations Relating to Taxable Issuance of Interest. Any income, gain, loss or deduction realized realized, by the Company as a direct or indirect result of the issuance of an Interest by the Company (the "“Issuance Items"”) shall be allocated among the Members Members, so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Member, shall be equal to the net amount that would have been allocated to each such Member if the Issuance Items had not been realized.
Appears in 2 contracts
Samples: Operating Agreement (Strategic Realty Trust, Inc.), Operating Agreement (Strategic Realty Trust, Inc.)
