Allocations Relating to Taxable Issuance of Partnership Interests. Any income, gain, loss, or deduction realized as a direct or indirect result of the issuance (or deemed issuance) of an Interest to a Partner (the “Issuance Items”) shall be allocated among the Partners so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Partner, shall be equal to the net amount that would have been allocated to each such Partner if the Issuance Items had not been realized.
Appears in 3 contracts
Samples: Limited Partnership Agreement (Evercore Partners Inc.), Limited Partnership Agreement (Evercore Partners Inc.), Limited Partnership Agreement (Evercore Partners Inc.)
Allocations Relating to Taxable Issuance of Partnership Interests. Any income, gain, loss, loss or deduction realized as a direct or indirect result of the issuance (or deemed issuance) of an Interest interest in the Partnership to a Partner (the “Issuance Items”) shall be allocated among the Partners so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Partner, shall be equal to the net amount that would have been allocated to each such Partner if the Issuance Items had not been realized.
Appears in 2 contracts
Samples: Limited Partnership Agreement (Silvercrest Asset Management Group Inc.), Limited Partnership Agreement (Silvercrest Asset Management Group Inc.)
Allocations Relating to Taxable Issuance of Partnership Interests. Any income, gain, loss, or deduction realized as a direct or indirect result of the issuance (or deemed issuance) of an Interest by the Partnership to a Partner (the “Issuance Items”) shall be allocated among the Partners so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Partner, shall be equal to the net amount that would have been allocated to each such Partner if the Issuance Items had not been realized.
Appears in 2 contracts
Samples: Limited Partnership Agreement (Hospital of Fulton, Inc.), Limited Partnership Agreement (Winder HMA, LLC)
Allocations Relating to Taxable Issuance of Partnership 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 the Partnership to a Partner other than pursuant to Code Section 707(a)(2) (the “Issuance Items”) shall be allocated among the Partners so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Partner, shall be equal to the net amount that would have been allocated to each such Partner if the Issuance Items had not been realized.
Appears in 2 contracts
Samples: Limited Partnership Agreement (Ims Health Inc), Limited Partnership Agreement (Global Media USA, LLC)
Allocations Relating to Taxable Issuance of Partnership Interests. Any income, gain, loss, or deduction realized as a direct or indirect result of the issuance (or deemed issuance) of an Interest interest in the Partnership to a Partner (the “Issuance Items”) shall be allocated among the Partners so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Partner, shall be equal to the net amount that would have been allocated to each such Partner if the Issuance Items had not been realized.
Appears in 1 contract
Samples: General Partnership Agreement (Seitel Ip Holdings, LLC)
Allocations Relating to Taxable Issuance of Partnership Interests. Any income, gain, loss, or deduction realized as a direct or indirect result of the issuance (or deemed issuance) of an Interest by the Partnership to a Partner (the “"Issuance Items”") shall be allocated among the Partners so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Partner, shall be equal to the net amount that would have been allocated to each such Partner if the Issuance Items had not been realized.
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Allocations Relating to Taxable Issuance of Partnership Interests. Any income, gain, loss, or deduction realized as a direct or indirect result of the issuance (or deemed issuance) of an Interest to a Partner (the “any Issuance Items”) Items shall be allocated among the Partners so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Partner, shall be equal to the net amount that would have been allocated to each such Partner if the Issuance Items had not been realized.
Appears in 1 contract
Samples: Limited Partnership Agreement (FNB Financial Services, LP)
Allocations Relating to Taxable Issuance of Partnership 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 the Partnership to a Partner (the “"Issuance Items”") shall be allocated among the Partners so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Partner, shall be equal to the net amount that would have been allocated to each such Partner if the Issuance Items had not been realized.. (i) [Intentionally omitted)
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