Allocations With Respect to Transferred Interests. Any Profit or Loss allocable to an interest in the Company which has been transferred during any year shall be allocated among the Persons who were holders of such interest during such year pursuant to any method under the Code or Treasury Regulations agreed upon by the Members.
Allocations With Respect to Transferred Interests. Unless otherwise required by the Code and/or the Regulations or as agreed to and by the Managing General Partner, in its sole and absolute discretion, any Net Income or Net Loss allocable to a Partnership Interest which has been transferred during any year shall be allocated among the Persons who were holders of such Partnership Interest during such year in the manner described in Section 11.6 below.
Allocations With Respect to Transferred Interests. Except as otherwise provided below or unless otherwise required by the provisions of the Code or agreed by the Members, any Profit or Loss allocable to an interest in the Company which has been transferred during any year shall be allocated among the Persons who were holders of such interest during such year in proportion to the number of days during such year that each holder was recognized as the holder of the interest, without regard to the results of Company operations during the period the holder was recognized as the owner thereof.
Allocations With Respect to Transferred Interests. Unless otherwise required by the provisions of the Code or agreed by the Manager, any Profit or Loss allocable to an interest in the Company which has been transferred during any year shall, except as provided below, be allocated among the Persons who were holders of such interest during such year in proportion to the number of days during such year that each holder was recognized as the holder of the interest, without regard to the results of Company operations during the period the holder was recognized as the owner thereof. Notwithstanding the foregoing, any Profit or Loss attributable to a sale, exchange or other disposition of all or substantially all of the assets of the Company shall be allocated to the holder of the interest on the date of the transaction generating such Profit or Loss.
Allocations With Respect to Transferred Interests. Profits and losses allocable to an Interest transferred or reissued during a Fiscal Year shall be allocated to each Person who was the holder of such Interest during such Fiscal Year, in proportion to the number of days that each such holder was recognized as the owner of such Interest during such Fiscal Year or by an interim closing of the books or in any other proportion permitted by the Code and selected by RCL Trust 1996-1 in accordance with this Agreement, without regard to the results of Lease Trust operations or the date, amount or recipient of any distributions which may have been made with respect to such Interest. The effective date of any transfer shall be (i) in the case of a voluntary transfer, the actual date the transfer is recorded on the books of the Lease Trust or (ii) in the case of involuntary transfer, the date of the operative event.
Allocations With Respect to Transferred Interests. If a Membership Interest has been Disposed of during a fiscal year, distributions shall be made, as among the party or parties Disposing of the Membership Interest (the “Transferor(s)”) and the party or parties to whom the Membership Interest is Disposed (the “Transferee(s)”), to the Person owning the Membership Interest on the date of the distribution. Profits, Losses and items allocated under this Section 5.7 (other than income or loss from a capital event) shall be allocated based on the closing of the books method under Code § 706, and Profits or Losses from any capital event shall be allocated to the holder of the Membership Interest on the day the capital event occurred during such fiscal year.
Allocations With Respect to Transferred Interests. Except as otherwise provided below or unless otherwise required by the provisions of the Code or agreed upon by a Super Majority of the Partners, any Profits or Losses allocable to an interest in the Partnership which has been transferred during any year shall be allocated among the Persons who were holders of such interest during such year in proportion to the number of days during such year that each holder was recognized as the holder of the interest, without regard to the results of Partnership operations during the period the holder was recognized as the owner thereof.
Allocations With Respect to Transferred Interests. If Partnership Interests are transferred in accordance with this Agreement, there shall be allocated to the transferor Partner and the transferee Partner during the fiscal year of transfer the product of: (i) the Partnership's Profits or Losses allocable to such Partnership Interest for such fiscal year; and (ii) a fraction, the numerator of which is the number of days such Partner held such Partnership Interest during such fiscal year and the denominator of which is the total number of days in such fiscal year; provided, however, that the Board of Directors may, in its sole discretion (subject to the provisions of Sections 706(d) of the Code), allocate such Profits or Losses by closing the books of the Partnership immediately after the transfer of such Partnership Interest, and provided further, in the case of the sale or other disposition of a Portfolio Investment, Profits or Losses from such sale or other disposition shall be allocated as of the date of such sale or other disposition and distributions of the net proceeds from such sale or other disposition shall be made to the parties who were Partners on the date of such sale or other disposition as if no transfer had been made and all Partners' Capital Accounts shall be adjusted accordingly.
Allocations With Respect to Transferred Interests. If Partnership Interests are transferred in accordance with this Agreement, there shall be allocated to the transferor Partner and the transferee Partner during the fiscal year of transfer the product of: (i) the Partnership's Profits or Losses allocable to such Partnership Interest for such fiscal year; and (ii) a fraction, the numerator of which is the number of days such Partner held such Partnership Interest during such fiscal year and the denominator of which is the total number of days in such fiscal year; provided, however, that the Board of Directors
Allocations With Respect to Transferred Interests. Upon transfer of all or any portion of the General Partner's interest in accordance with this Section 13 during a Partnership taxable year and the admission of a new general partner or general partners, the items of Partnership income, gain, loss or deduction allocable to the General Partner's interest during the year shall be shared among the persons who were general partners during the year in any manner consistent with the requirements of Code Section 706(d) that the general partner or general partners having the obligation to file the Partnership's federal income tax return for such year under Section 12 shall determine, provided, however, that portion of the gain or loss from the sale or the taxable disposition of a Partnership capital asset that is allocable to the general partner's interest in the Partnership shall be allocated to the person or persons who held that interest on the day such gain or loss was recognized by the Partnership. General Partner shall provide an opinion of counsel, in the form and substance satisfactory to counsel for both Partnership and Limited Partner, that neither the offering nor assignment of the General Partner's interest in the Partnership violates any provision of any federal or state securities or comparable law, and that such transfer will not cause the termination of the Partnership for federal income tax purposes nor limit or reduce Limited Partner's cash flow, extraordinary or otherwise, Unrepaid Capital Contributions, if any, or cash proceeds, if any. The General Partner shall be responsible for all expenses relating to the transfer of any portion of the General Partner's interest in the Partnership.
