Allocations Relating to Taxable Issuance of 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 this Operating 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.
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Samples: Operating Agreement, LLC Operating Agreement, Operating Agreement
Allocations Relating to Taxable Issuance of Interests. Any item of income, gain, loss, or deduction realized as a direct or indirect result of the issuance of an Interest by the Company Partnership to a Member Partner (the "Issuance Items") shall be allocated among the Members Partners so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Operating Agreement made to each Member Partner pursuant to this Agreement, shall be equal to the net amount that would have been allocated to each such Member Partner if the Issuance Items had not been realized.
Appears in 2 contracts
Samples: Limited Partnership Agreement (Terra Industries Inc), Agreement of Limited Partnership (Terra Industries Inc)
Allocations Relating to Taxable Issuance of Interests. Any income, gain, 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"”) 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 Operating Agreement to each Member 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: LLC Operating Agreement (Endexx Corp), LLC Operating Agreement (Endexx Corp)
Allocations Relating to Taxable Issuance of 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 (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 Operating Agreement to each Member 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 1 contract
Samples: Limited Liability Company Agreement (BRT Realty Trust)
Allocations Relating to Taxable Issuance of Interests. Any income, gain, loss, loss or deduction realized by the Company as a direct or indirect result of the issuance of an Interest Units by the Company to a Member (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 Operating Agreement to each Member 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.
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Allocations Relating to Taxable Issuance of 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 other than pursuant to Section 707(a)(2) of the Code (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 Operating 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.
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Allocations Relating to Taxable Issuance of Interests. Any income, gain, loss, loss or deduction realized by the Company as a direct or indirect result of the issuance of an Interest Units by the Company to a Member (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 Operating Agreement to each Member 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 1 contract
Allocations Relating to Taxable Issuance of Interests. Any income, gain, loss, loss or deduction realized by the Company as a direct or indirect result of the issuance of an Interest Units by the Company to a Member (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 Operating Agreement to each Member 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.
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Allocations Relating to Taxable Issuance of Interests. Any income, gain, loss, loss or deduction realized as a direct or indirect result of the issuance (or deemed 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 this Operating Agreement to each Member 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 1 contract
Samples: Limited Liability Company Agreement (China Hydroelectric Corp)