Allocations to Shareholders. (a) Items of income, deduction, gain, loss or credit of each Series will be allocated for federal income tax purposes among the Shareholders of that Series in a manner so as to reflect equitably amounts credited or debited to each Shareholder's Book Capital Account for that Series for the current and prior taxable years (or relevant portions of those years). Allocations under this Section 11.02(a) will be made in accordance with the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Treasury Regulations promulgated under these sections, or the successor provisions to such sections and Treasury Regulations.
Appears in 5 contracts
Samples: Limited Liability Company Agreement (Fidelity Central Investment Portfolios II LLC), Limited Liability Company Agreement (Fidelity Central Investment Portfolios LLC), Limited Liability Company Agreement (Fidelity Central Investment Portfolios LLC)
Allocations to Shareholders. (a) Items of income, deduction, gain, loss or credit of each Series will be allocated for federal income tax purposes among the Shareholders of that Series in a manner so as to reflect equitably amounts credited or debited to each Shareholder's ’s Book Capital Account for that Series for the current and prior taxable years (or relevant portions of those years). Allocations under this Section 11.02(a) will be made in accordance with the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Treasury Regulations promulgated under these sections, or the successor provisions to such sections and Treasury Regulations.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Fidelity Central Investment Portfolios II LLC)
Allocations to Shareholders. (a) Items of income, deduction, gain, loss or credit of each Series will be allocated for federal income tax purposes among the Shareholders of that Series in a manner so as to reflect equitably amounts credited or debited to each Shareholder's Shareholders Book Capital Account for that Series for the current and prior taxable years (or relevant portions of those years). Allocations under this Section 11.02(a) will be made in accordance with the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Treasury Regulations promulgated under these sections, or the successor provisions to such sections and Treasury Regulations.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Fidelity Central Investment Portfolios II LLC)