Apportionment of Income and Loss Sample Clauses

Apportionment of Income and Loss. For purposes of apportioning taxable income or loss relating to any taxable period that ends on the Closing Date ("SHORT TAX PERIOD") and for that portion of any taxable year that includes (but that does not end on) the Closing Date (a "PARTIAL TAX PERIOD"), such taxable income or loss will be determined by reference to the operations of the Acquired Companies through the Closing Date as though it were the last day of a taxable year. If required, appropriate elections will be made with applicable taxable authorities to accomplish such result.
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Apportionment of Income and Loss. For purposes of apportioning taxable income or loss relating to any taxable period that ends on the day immediately preceding the Effective Date ("Short Tax Period") and for that portion of any taxable year that includes (but that does not end on) the day immediately preceding the Effective Date (a "Partial Tax Period"), such taxable income or loss shall be determined by reference to the operations of the Company through the day immediately preceding the Effective Date as though it were the last day of a taxable year under Treasury Regulation Section 1.1502-76(b). If required, appropriate elections shall be made with applicable taxable authorities to accomplish such result.
Sample 1

Related to Apportionment of Income and Loss

  • Allocations of Income and Loss For each taxable year, each holder of Preferred Units will be allocated a portion of the Net Income and Net Loss of the Partnership equal to the portion of the Net Income and Net Loss of the Partnership that would be allocated to such holder pursuant to Article 6 of the Agreement if such holder held a number of Partnership Common Units equal to (i) the number of Preferred Units held by such holder, multiplied by (ii) 0.625. Upon liquidation, dissolution or winding up of the Partnership, the Partnership shall endeavor to allocate income and gain to the holders of the Preferred Units such that the Capital Accounts related to the Preferred Units are equal to their Liquidation Preference.

  • Apportionment of Earnings and Profits and Tax Attributes (a) Tax Attributes arising in a Pre-Distribution Period will be allocated to (and the benefits and burdens of such Tax Attributes will inure to) the members of the Parent Group and the members of the SpinCo Group in accordance with the Code, Treasury regulations and any other Applicable Tax Law, and, in the absence of controlling legal authority or unless otherwise provided under this Agreement, Tax Attributes shall be allocated to the legal entity that created such Tax Attributes.

  • Allocation of Profits and Losses The Company’s profits and losses shall be allocated to the Member.

  • Allocation of Profit and Loss Article V, Section 5.01 of the Partnership Agreement is hereby deleted in its entirety and the following new Section 5.01 is inserted in its place:

  • Profits and Losses For financial accounting and tax purposes, the Company’s net profits or net losses shall be determined on an annual basis in accordance with the manner determined by the Board. In each year, profits and losses shall be allocated entirely to the Member.

  • Net Income and Net Loss All net income or net loss of the Company shall be for the account of the Member.

  • Net Losses After giving effect to the special allocations set forth in Section 6.1(d), Net Losses for each taxable period and all items of income, gain, loss and deduction taken into account in computing Net Losses for such taxable period shall be allocated as follows:

  • Profits and Losses Distributions The Member shall treat all of the profits and losses of the Company as its own. All distributions shall be made to the Member at times and in amounts determined by the Member or the Board of Managers. The Company shall not make distributions to the Member if such distribution would violate Section 18-607 of the Act.

  • Items of Income or Loss Except as is otherwise provided in this Exhibit B, an allocation of Partnership Net Income or Net Loss to a Partner shall be treated as an allocation to such Partner of the same share of each item of income, gain, loss, deduction and item of tax-exempt income or Section 705(a)(2)(B) expenditure (or item treated as such expenditure pursuant to Regulations Section 1.704-1(b)(2)(iv)(i)) (“Tax Items”) that is taken into account in computing Net Income or Net Loss.

  • Net Loss After giving effect to the special allocations set forth in Section 6.1(d), Net Loss for each taxable period and all items of income, gain, loss and deduction taken into account in computing Net Loss for such taxable period shall be allocated as follows:

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