Allocations Solely for Tax Purposes. Allocations pursuant to this Section 4.7 are solely for purposes of federal, state and local taxes and shall not affect, or in any way be taken into account in computing, any Partner’s Capital Account or share of Profits and Losses or other items or distributions pursuant to any provision of this Agreement.
Allocations Solely for Tax Purposes. Items of income, gain, deduction, loss, and credit for federal income tax purposes shall be allocated among the Members in the same proportions as the corresponding book items are allocated, but if there is a book/tax difference in the determination of any such items by reason of a Member’s contribution of property having a value that varies from its adjusted tax basis, or by reason of any event on account of which assets are marked to market on the Company’s books under the principles of Section 1.704-1(b)(2)(iv)(f) of the Regulations, then such difference shall be reconciled in accordance with the principles of Section 704(c) of the Code and the Regulations thereunder using any permissible method selected by the Manager. Allocations pursuant to this Section 3.3 are solely for tax purposes and shall not affect the Members’ Capital Accounts.
Allocations Solely for Tax Purposes. In accordance with IRC §704(c) and the corresponding regulations, income, gain, loss, and deduction with respect to any property contributed to the capital of the Company will be allocated among the Members, solely for income tax purposes, so as to take into account any variation between the adjusted basis of such property for federal income tax purposes in the hands of the Company and the agreed value of such property as set forth in this agreement, or in any document entered into at the time an additional contribution is made to the Company. Any elections or other decisions relating to the allocations to be made under this section will be made by action of the Members. The allocations to be made under this section are solely for purposes of federal, state, and local income taxes and will not affect, or in any way be taken into account in computing, any Member's capital account, allocable share of the net profits and net losses of the Company, or right to distributions.
Allocations Solely for Tax Purposes. Allocations pursuant to this Article IX are solely for purposes of U.S. federal, state and local taxes and, except as otherwise specifically provided, shall not affect, or in any way be taken into account in computing, any Member’s Capital Account or share of Profits, Losses, other items or distributions pursuant to any provision of this Agreement.
Allocations Solely for Tax Purposes. Items of income, gain, deduction, loss, and credit for federal income tax purposes shall be allocated between the Members in the same proportions as the corresponding book items are allocated, but if there is a book/tax difference in the determination of any such items by reason of a Member’s contribution (or deemed contribution) of property (including, without limitation, T-Asia’s capital contribution deemed made pursuant to Section 2.2 hereof) having a value that varies from its adjusted tax basis, or by reason of any event on account of which assets are marked-to-market on the Company’s book under the principles of Section 1.704-1(b)(2)(iv)(f) of the Regulations, then such difference shall be reconciled in accordance with the principles of Section 704(c) of the Code and the regulations thereunder using any permissible method selected by the Manager. Allocations pursuant to this Section 3.3 are solely for tax purposes, and shall not affect the Members’ Capital Accounts.
Allocations Solely for Tax Purposes. 6.4.1 Allocations required under this Section 6.4 are solely for tax purposes and shall not affect any Partner’s Capital Account or any Partner’s share of any distribution from the Partnership.
Allocations Solely for Tax Purposes. In accordance with IRC §704(c), income, gain, loss, and deduction with respect to any property contributed to the capital of the company must be allocated among the members to take into account any variation between the adjusted basis of the property for federal income tax purposed in the hands of the company and the agreed value of the property as set forth in this agreement, or in any document entered into at the time additional property or other capital is contributed to the company. Any elections or other decisions relating to the allocations to be made under this section will be made by the members. The allocations to be made under this section are solely for income tax purposes and will not affect any member’s capital account, allocable share of the net profits and net losses, or right to distributions.
Allocations Solely for Tax Purposes. In accordance with Section 704(c) of the Code, and the Regulations thereunder, income, gain, loss and deduction with respect to any property contributed to the capital of the Company shall, solely for tax purposes, be allocated between the Members so as to take account of any variation between the fair market value and adjusted tax basis of such asset at the time of such contribution. Accordingly, any taxable gain recognized by the Company on the sale or other disposition of the interests in TCA contributed by the Members shall be allocated (i) first, to each Member in the amount by which the fair market value of the interest in TCA contributed by such Member to the Company exceeds such Member's tax basis in such interest at the time of contribution, and (ii) then, between the Members, pro rata, the ratio in which the book gain on such sale or other disposition is allocated between them pursuant to Section 4.1 hereof; provided, however, that if taxable gain on such sale or other disposition is reported on the installment method for federal income tax purposes, then any such taxable gain reported for a fiscal year shall be allocated between the Members in the ratio that all such taxable gain would have been allocable between the Members in the year of such sale or other disposition pursuant to this Section 4.2 if the installment method of reporting had been inapplicable.
Allocations Solely for Tax Purposes. (a) Each item of income, gain, loss or deduction entering into the computation of the Company’s profit and loss as determined for federal income tax purposes shall be allocated among the Members in the same proportions as the corresponding items are allocated for capital accounting (“book”) purposes, except as provided below in this Section 9.3.
Allocations Solely for Tax Purposes. (a) In the event of the death of a Member, or the transfer of a Member's Membership Interest by sale or exchange, the Company shall, if the person acquiring such Membership Interest so requests and if the manager agrees to do so, elect, pursuant to Section 754 of the Code, or any corresponding provision of succeeding law, to adjust the basis of the Company's property. Any change in the gain or loss of the Company for federal income tax purposes resulting from such election shall be allocated entirely to the transferee of the Membership Interest so transferred; provided, however, neither the Membership Interest nor the amount of any cash distributions to the Members shall be affected as a result of such election, and the making of such election shall have no effect except for federal income tax purposes. Each Member agrees to furnish the Company with all information necessary to give effect to such election, and each Member affected by such election agrees to bear all accounting and other costs of determining and reporting the effect of such election on such Member.
