Allocations Relating to Taxable Issuance of Units. Any income, gain, loss or deduction realized as a direct or indirect result of the issuance of Units by the Company to a Unit Holder (the “Issuance Items”) shall be allocated among the Unit Holders so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Unit Holder shall be equal to the net amount that would have been allocated to each such Unit Holder if the Issuance Items had not been realized.
Appears in 9 contracts
Samples: Operating Agreement, Operating Agreement, Member Control Agreement (Granite Falls Energy, LLC)
Allocations Relating to Taxable Issuance of Units. Any income, gain, loss or deduction realized as a direct or indirect result of the issuance of Units by the Company to a Unit Holder (the “Issuance Items”) shall be allocated among the Unit Holders so that, to the extent possible, the net amount of such Issuance Itemsitems, together with all other allocations under this Agreement to each Unit Holder shall be equal to the net amount that would have been allocated to each such Unit Holder if the Issuance Items items had not been realized.
Appears in 4 contracts
Samples: Operating Agreement (Minnesota Corn Processors LLC), Operating Agreement (Minnesota Corn Processors LLC), Operating Agreement (Minnesota Corn Processors LLC)
Allocations Relating to Taxable Issuance of Units. Any income, gain, loss or deduction realized as a direct or indirect result of the issuance of Units by the Company to a Unit Holder Member (the “Issuance Items”) shall be allocated among the Unit Holders Members so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Unit Holder Member, shall be equal to the net amount that would have been allocated to each such Unit Holder Member if the Issuance Items had not been realized.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (BFC Financial Corp), Stock Purchase Agreement (Bankatlantic Bancorp Inc), Limited Liability Company Agreement (Bankatlantic Bancorp Inc)
Allocations Relating to Taxable Issuance of Units. Any income, gain, loss loss, or deduction realized as a direct or indirect result of the issuance of Units by the Company to a Unit Holder Member (the “Issuance Items”) shall be allocated among the Unit Holders Members so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Unit Holder Member shall be equal to the net amount that would have been allocated to each such Unit Holder Member if the Issuance Items had not been realized.
Appears in 2 contracts
Samples: Business Combination Agreement (Spree Acquisition Corp. 1 LTD), Limited Liability Company Agreement (OPAL Fuels Inc.)
Allocations Relating to Taxable Issuance of Units. Any income, gain, loss or deduction realized as a direct or indirect result of the issuance of Units an interest in the Company by the Company to a Unit Holder Member (the “Issuance Items”) shall be allocated among the Unit Holders Members so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Unit Holder Member, shall be equal to the net amount that would have been allocated to each such Unit Holder Member if the Issuance Items had not been realized.
Appears in 2 contracts
Samples: Operating Agreement (PERRIGO Co PLC), Operating Agreement (PERRIGO Co PLC)
Allocations Relating to Taxable Issuance of Units. Any income, gain, loss or deduction realized as a direct or indirect result of the issuance of Units by the Company to a Unit Holder (the “"Issuance Items”") shall be allocated among the Unit Holders so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Unit Holder shall be equal to the net amount that would have been allocated to each such Unit Holder if the Issuance Items had not been realized.
Appears in 1 contract
Samples: Operating Agreement
Allocations Relating to Taxable Issuance of Units. Any income, gain, loss or deduction realized as a direct or indirect result of the issuance of Units a Unit by the Company to a Unit Holder Member (the “"Issuance Items”") shall be allocated among the Unit Holders Members so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Unit Holder Member, shall be equal to the net amount that would have been allocated to each such Unit Holder Member if the Issuance Items had not been realized.
Appears in 1 contract
Samples: Limited Liability Company Agreement (WPT Enterprises Inc)
Allocations Relating to Taxable Issuance of Units. Any income, gain, loss or deduction realized as a direct or indirect result of the issuance of Units by the Company to a Unit Holder (the “Issuance Items”) Member shall be allocated among the Unit Holders Members so that, to the extent possible, the net amount of such Issuance Itemsincome, gain, loss or deduction, together with all other allocations under this Agreement to each Unit Holder Member shall be equal to the net amount that would have been allocated to each such Unit Holder Member if the Issuance Items such income, gain, loss or deduction had not been realized.
Appears in 1 contract
Allocations Relating to Taxable Issuance of Units. Any income, gain, loss or deduction realized as a direct or indirect result of the issuance of Units an interest by the Company to a Unit Holder (the “Issuance Items”) Member shall be allocated among the Unit Holders Members so that, to the extent possible, the net amount of such Issuance Itemsitems, together with all other allocations under this Agreement to each Unit Holder Member, shall be equal to the net amount that would have been allocated to each such Unit Holder Member if the Issuance Items such items had not been realized.
Appears in 1 contract
Samples: Operating Agreement
Allocations Relating to Taxable Issuance of Units. Any income, gain, loss or deduction realized as a direct or indirect result of the issuance of Units by the Company to a Unit Holder Member (the “Issuance Items”) shall be allocated among the Unit Holders Members so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Unit Holder Member shall be equal to the net amount that would have been allocated to each such Unit Holder Member if the Issuance Items had not been realized.
Appears in 1 contract
Samples: Preferred Unit Purchase Agreement (Elandia International Inc.)
Allocations Relating to Taxable Issuance of Units. Any income, gain, loss or deduction realized as a direct or indirect result of the issuance of Units an interest by the Company to a Unit Holder (the “Issuance Items”) Member shall be allocated among the Unit Holders Members so that, to the extent possible, the net amount of such Issuance Itemsitems, together with all other allocations under this Agreement to each Unit Holder Member, shall be equal to the net amount that would have been allocated to each such Unit Holder Member if the Issuance Items such items had not been realized. Distributions .
Appears in 1 contract
Samples: Operating Agreement
Allocations Relating to Taxable Issuance of Units. Any income, gain, loss or deduction realized as a direct or indirect result of the issuance of Units by the Company to a Unit Xxxx Holder (the “Issuance Items”) shall be allocated among the Unit Holders so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Unit Holder shall be equal to the net amount that would have been allocated to each such Unit Holder if the Issuance Items had not been realized.
Appears in 1 contract
Samples: Member Control Agreement (Heron Lake BioEnergy, LLC)
Allocations Relating to Taxable Issuance of Units. Any income, gain, loss loss, or deduction realized as a direct or indirect result of the issuance of Units by the Company Plan to a Unit Holder Member (the “Issuance Items”) shall be allocated among the Unit Holders Members so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Unit Holder Member shall be equal to the net amount that would have been allocated to each such Unit Holder Member if the Issuance Items had not been realized.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Viant Technology Inc.)
Allocations Relating to Taxable Issuance of Units. Any income, gain, loss or deduction realized as a direct or indirect result of the issuance of Units a Unit by the Company to a Unit Holder Member (the “Issuance Items”) shall be allocated among the Unit Holders so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Unit Holder Holder, shall be equal to the net amount that would have been allocated to each such Unit Holder if the Issuance Items had not been realized.
Appears in 1 contract
Allocations Relating to Taxable Issuance of Units. Any income, gain, loss loss, or deduction realized as a direct or indirect result of the issuance of Units a Unit by the Company to a Unit Holder Member (the “"Issuance Items”") shall be allocated among the Unit Holders Members so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Unit Holder Member, shall be equal to the net amount that would have been allocated to each such Unit Holder Member if the Issuance Items had not been realized.
Appears in 1 contract
Allocations Relating to Taxable Issuance of Units. Any income, gain, ------------------------------------------------- loss or deduction realized by the Company as a direct or indirect result of the issuance of Units a Unit by the Company to a Unit Holder (the “"Issuance Items”") shall be allocated among the Unit Holders Members, so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Unit Holder Member, shall be equal to the net amount that would have been allocated to each such Unit Holder Member if the Issuance Items had not been realized.
Appears in 1 contract
Samples: Operating Agreement (Switzerland County Development Corp)
Allocations Relating to Taxable Issuance of Units. Any income, gain, loss loss, or deduction realized as a direct or indirect result of the issuance of Units by the Company to a Unit Holder Member (the “Issuance Items”) shall be allocated among the Unit Holders Members so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement Exhibit A to each Unit Holder Member shall be equal to the net amount that would have been allocated to each such Unit Holder Member if the Issuance Items had not been realized.
Appears in 1 contract
Samples: Operating Agreement (KonaTel, Inc.)
