Compliance with Code. The foregoing provisions of this Article relating to the allocation of Profits, Losses and other items for federal income tax purposes are intended to comply with Treasury Regulations Sections 1.704-1(b) and 1.704-2, and shall be interpreted and applied in a manner consistent with such Treasury Regulations. Notwithstanding anything to the contrary, nothing in this Article shall apply if it lacks "economic effect."
Appears in 15 contracts
Samples: Limited Partnership Agreement (Cornell Corrections of Rhode Island, Inc.), Limited Partnership Agreement (Cornell Corrections of Rhode Island, Inc.), Limited Partnership Agreement (Fiber Glass Systems Lp)
Compliance with Code. The foregoing provisions of this Article relating to the allocation of Profits, Losses Loses and other items for federal income tax purposes are intended to comply with Treasury Regulations Sections Section 1.704-1(b) and 1.704-2, and shall be interpreted and applied in a manner consistent with such Treasury Regulations. Notwithstanding anything to the contrary, nothing in this Article shall apply if it lacks "economic effect."
Appears in 1 contract
Samples: Company Agreement (Golfsmith International Holdings Inc)
Compliance with Code. The foregoing provisions of this Article relating to the allocation of Profits, Losses and other items for federal income tax purposes are intended to comply with Treasury Regulations Sections 1.704-1(b) and 1.704-2, and shall be interpreted and applied in a manner consistent with such Treasury Regulations. Notwithstanding anything to the contrary, nothing in this Article shall apply if it its lacks "economic effect."
Appears in 1 contract
Samples: Company Agreement (Golfsmith International Holdings Inc)
Compliance with Code. The foregoing provisions of this Article relating to the allocation of Profits, Losses and other items for federal income tax purposes are intended to comply with Treasury Regulations Sections 1.704-1(b) and 1.704-2, and shall be interpreted and applied in a manner consistent with such Treasury Regulations. Notwithstanding anything to the contrary, nothing in this Article shall apply if it lacks "“economic effect."”
Appears in 1 contract
Compliance with Code. The foregoing provisions of this Article IV relating to the allocation of Profits, Losses Losses, and other items for federal income tax purposes purposes, are intended to comply with Treasury Regulations Sections 1.704-1(b) and 1.704-2, and shall be interpreted and applied in a manner consistent with such Treasury Regulations. Notwithstanding anything to the contrary, nothing in this Article IV shall apply if it lacks "“economic effect”."
Appears in 1 contract
Samples: Company Agreement
