Amendment of Allocation Provisions. The provisions of this Agreement relating to the maintenance of Capital Accounts and the method of accounting, including the capital account maintenance rules and allocation of Profits and Losses, may be amended at any time by the General Partner only to the extent necessary, in the opinion of tax counsel to the Partnership, to ensure that the allocations hereunder will be respected by the Israeli Income Tax Authorities. All other decisions concerning the allocation of profits, gains and losses among the Partners pursuant to the terms of this Agreement not specifically and expressly provided for by the terms of this Agreement shall be made by the General Partner, but subject to the approval of the Exceptions Committee.
Amendment of Allocation Provisions. A-13 SECTION 6.06. Distributions............................................... A-13
Amendment of Allocation Provisions. To preserve uniformity of Units (or any class or classes thereof), to provide for the admission or withdrawal of a partner, to comply with applicable rules and regulations under Section 704 of the Code, or for the proper administration of the Partnership, including, without limitation, the allocation of income between a transferor and a transferee of Units, the General Partner may, in its sole discretion, (i) amend the provisions of this Agreement (including the provisions of Sections 5.02, 6.02, 6.03 and 6.04) and make special allocations of gross income or deductions as appropriate; provided, however, that such amendments or allocations would not unfairly discriminate against any Limited Partner and that the allocations as so amended would be consistent with the principles of Section 704 of the Code; and (ii) adopt such conventions as it deems appropriate in making allocations of depreciation and cost recovery deductions and in allocating income, gain, loss, deduction and credit between transferors and transferees of Units (in accordance with Section 13.04 hereof). If the General Partner determines, based on advice of counsel, that no reasonable convention or method is available to preserve uniformity of Units (or any class or classes thereof) under this Section 6.05, and the General Partner in its sole discretion so elects, the Units may be separately identified as distinct classes to reflect differences in tax or economic attributes.
Amendment of Allocation Provisions. 14 Section 6.06.
Amendment of Allocation Provisions. To preserve uniformity of Units and to comply with applicable rules and regulations for the allocation of income between a transferor and a transferee of Units, the General Partner may, in its sole discretion, amend the provisions of this Agreement (including the provisions of Sections 6.02, 6.03 and 6.04 hereof) as appropriate; provided, however, that no such amendment would have a material adverse effect on the Limited Partners and that the allocations as so amended would be more consistent with the principles of Section 704 of the Code.
