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

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.

Appears in 3 contracts

Samples: Operating Agreement, Operating Agreement, Operating Agreement

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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 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 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: Terra Industries Inc, Terra Industries Inc

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.

Appears in 1 contract

Samples: Operating Agreement (155 East Tropicana, LLC)

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.

Appears in 1 contract

Samples: Operating Agreement (Vistancia Marketing, LLC)

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)

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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 of an Interest by the Company Partnership to a Member Partner (the "Issuance Items") shall be allocated among the Members General Partner and other Interest Holders 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 Interest Holder, shall be equal to the net amount that would have been allocated to each such Member Interest Holder if the Issuance Items had not been realized.

Appears in 1 contract

Samples: San Juan Refining Co.

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

Samples: Operating Agreement (155 East Tropicana, LLC)

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

Samples: Operating Agreement (Siena Technologies, Inc.)

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