Computation of Income or Loss for Tax Purposes Sample Clauses

Computation of Income or Loss for Tax Purposes. The General Partner shall have the right, in computing the income or loss of the Partnership for tax purposes, to adopt a different method of computation than required by Section 6.1, to adopt different treatments of particular items and to make and revoke such elections on behalf of the Partnership and the Partners as the General Partner deems to be appropriate in order to reflect and give effect to the terms of this Agreement; provided that the same method or treatment shall be adopted and the same elections shall be made and revoked in respect of all Limited Partners and, if applicable, the General Partner.
Sample 1
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Computation of Income or Loss for Tax Purposes. (a) The Manager shall have the right, in computing the income or loss of the Partnership for tax purposes, to adopt a different method of accounting than GAAP, to adopt different treatments of particular items, and to make and revoke such elections on behalf of the Partnership and the Partners as the Manager deems to be appropriate to reflect the terms of this Agreement. (b) All income, gains, losses and deductions of the Partnership shall be allocated among the Limited Partners in accordance with the allocation of such income, gains, losses and deductions among the Limited Partners for computing their Capital Accounts, except that, if any such allocation for tax purposes is not permitted by the Tax Act, the Partnership's subsequent income, gains, losses and deductions shall be allocated among the Limited Partners for tax purposes, to the extent permitted by the Tax Act, so as to reflect as nearly as possible the allocation set forth herein in computing their Capital Accounts. (c) Allocations under Section 6.3(b) are solely for purposes of federal and state taxes and shall not affect, or in any way be taken into account in computing, any Limited Partner's Capital Account or share of Net Profits, Net Losses, distributions or other items under any provisions of this Agreement. (d) The Manager may, if any allocation is successfully challenged by the relevant taxing authority, notwithstanding the foregoing, but acting reasonably, adjust the amount of Net Profits or Net Losses allocated, including the allocation of any income or loss for tax purposes, to the extent it determines that such adjusted amounts better reflect the substantive economic entitlements of the Limited Partners. The Manager will claim discretionary deductions to the maximum extent available pursuant to applicable tax laws including the Tax Act, and will take all such reasonable steps to ensure that all such discretionary deductions with respect to the Mortgage Investments are claimed to the maximum extent permitted by applicable tax law.
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Computation of Income or Loss for Tax Purposes. The General Partner.
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Computation of Income or Loss for Tax Purposes. The General Partner shall have the right, in computing the income or loss of the Partnership for tax purposes, to adopt a different method of accounting than required by Section 12.1, to adopt different treatments of particular items and to make and revoke elections on behalf of the Partnership and the Legal*7421044.1 Partners as the General Partner may deem in the best interests of the Partners. In respect of any Fiscal Year, the General Partner intends to claim the maximum capital cost allowances in respect of depreciable property of the Partnership, the maximum amount of other deductions and maximum reserves as permitted under the Tax Act, provided that the General Partner may claim less than the maximum in any Fiscal Year if it considers that to do so would be in the best interests of the Limited Partners.
Sample 1
Computation of Income or Loss for Tax Purposes. Notwithstanding the definition of Net Income or Net Loss, for the purposes of recognition of income for tax purposes, income will be deferred for the length of time and recognized in the amount, and in the case of a deduction from income, such deduction will be taken at the time and in the amount, all as are determined by the General Partner, acting reasonably, to be advisable and in the best interests of the Limited Partners.
Sample 1
Computation of Income or Loss for Tax Purposes. In computing the income or loss of the Partnership for tax purposes, the General Partner shall compute the income or loss of the Partnership in accordance with the provisions of the ITA (and, if required, any applicable provincial taxing statute) and shall have the right to make and revoke such elections on behalf of the Partnership and the Partners as the General Partner deems to be appropriate in order to reflect the terms of this Agreement. Unless otherwise approved by Special Approval of the Partners, the Partnership shall be able to deduct, in the discretion of the General Partner, an amount of capital cost allowance available in each and every taxation year with respect to the capital cost and any improvements relating to the Plant with respect to which capital cost allowance is available.
Sample 1
Computation of Income or Loss for Tax Purposes. Unless otherwise directed by the GP Board, the Operator may, in computing the income or loss of the Partnership for tax purposes, adopt a method of accounting, adopt different treatments of particular items and make and revoke elections on behalf of the Partnership and the Partners as the Operator may deem in the best interests of the Partners, acting reasonably. In respect of any Fiscal Year, the Operator shall claim the maximum capital cost allowances in respect of depreciable property of the Partnership, and the maximum amount of other deductions and maximum reserves as permitted under the Tax Act, provided that, unless otherwise directed by the GP Board, the Operator may claim less than the maximum in any Fiscal Year if it considers that to do so would be in the best interests of the Partners.
Sample 1
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Computation of Income or Loss for Tax Purposes. In computing the income or loss of the Partnership for tax purposes, the General Partner shall compute the income or loss of the Partnership in accordance with the provisions of the ITA (and, if required, any applicable provincial taxing statute) and shall have the right to adopt a different method of accounting than required by Section 5.1, to adopt different treatments of particular items and to make and revoke such elections on behalf of the Partnership and the Partners as the General Partner deems to be appropriate in order to reflect the terms of this Agreement. Unless otherwise Approved by the Partners and subject to the at-risk amount rules provided in Section 96 of the ITA, the Partnership shall deduct the maximum capital cost allowance available in each and every taxation year with respect to the capital cost and any improvements relating to the Project with respect to which capital cost allowance is available.
Sample 1
Computation of Income or Loss for Tax Purposes. The General Partner may, in computing the income or loss of the Fund for tax purposes, adopt a different method of accounting than required by Section 14.9 (Determination of Net Income or Loss.), adopt different treatments of particular items, and make and revoke such elections on behalf of the Fund and the Partners as the General Partner deems to be appropriate in order to reflect the terms of this Agreement, provided that the same method or treatment shall be adopted and the same elections shall be made and revoked in respect of all Limited Partners.
Sample 1

Related to Computation of Income or Loss for Tax Purposes

  • Adjustments for Tax Purposes Any payments made pursuant to Section 2.04 shall be treated as an adjustment to the Purchase Price by the parties for Tax purposes, unless otherwise required by Law.

  • Allocations for Tax Purposes (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of "book" income, gain, loss or deduction is allocated pursuant to Section 6.1. (b) In an attempt to eliminate Book-Tax Disparities attributable to a Contributed Property or Adjusted Property, items of income, gain, loss, depreciation, amortization and cost recovery deductions shall be allocated for federal income tax purposes among the Partners as follows: (i) (A) In the case of a Contributed Property, such items attributable thereto shall be allocated among the Partners in the manner provided under Section 704(c) of the Code that takes into account the variation between the Agreed Value of such property and its adjusted basis at the time of contribution; and (B) any item of Residual Gain or Residual Loss attributable to a Contributed Property shall be allocated among the Partners in the same manner as its correlative item of "book" gain or loss is allocated pursuant to Section 6.1. (ii) (A) In the case of an Adjusted Property, such items shall (1) first, be allocated among the Partners in a manner consistent with the principles of Section 704(c) of the Code to take into account the Unrealized Gain or Unrealized Loss attributable to such property and the allocations thereof pursuant to Section 5.5(d)(i) or 5.5(d)(ii), and (2) second, in the event such property was originally a Contributed Property, be allocated among the Partners in a manner consistent with Section 6.2(b)(i)(A); and (B) any item of Residual Gain or Residual Loss attributable to an Adjusted Property shall be allocated among the Partners in the same manner as its correlative item of "book" gain or loss is allocated pursuant to Section 6.1. (iii) The General Partner shall apply the principles of Treasury Regulation Section 1.704-3(d)

  • Adjustment for Tax Purposes The Company shall be entitled to make such reductions in the Conversion Price, in addition to those required by Section 4.6, as it in its discretion shall determine to be advisable in order that any stock dividends, subdivisions of shares, distributions of rights to purchase stock or securities or distributions of securities convertible into or exchangeable for stock hereafter made by the Company to its stockholders shall not be taxable.

  • Disposition of Income During the term of this Trust, all income received by the Trust, net of expenses and taxes, shall be accumulated and reinvested.

  • Allocation of Net Income and Net Loss Net Income or Net Loss of the Partnership shall be determined as of the end of each calendar year and as of the end of any interim period extending through the day immediately preceding any (i) disproportionate Capital Contribution, (ii) disproportionate distribution, (iii) Transfer of a Partnership Interest in accordance with the terms of this Agreement, or (iv) Withdrawal Event. If a calendar year includes an interim period, the determination of Net Income or Net Loss for the period extending through the last day of the calendar year shall include only that period of less than twelve (12) months occurring from the day immediately following the last day of the latest interim period during the calendar year and extending through the last day of the calendar year. For all purposes, including income tax purposes, Net Income, if any, of the Partnership for each calendar year or interim period shall be allocated among the Partners in proportion to their respective Partnership Percentages for the calendar year or interim period. In the event of a Net Loss for a particular calendar year or interim period, then, for such calendar year or interim period, the Net Loss for such calendar year or interim period shall be allocated among the Partners in proportion to their respective Partnership Percentages for the calendar year or interim period.

  • How Are Contributions to a Xxxx XXX Reported for Federal Tax Purposes You must file Form 5329 with the IRS to report and remit any penalties or excise taxes. In addition, certain contribution and distribution information must be reported to the IRS on Form 8606 (as an attachment to your federal income tax return.)

  • Allocation of Profit or Loss All Profit or Loss shall be allocated to the Member.

  • Minimum Consolidated Net Worth The Borrower will not permit its Consolidated Net Worth at any time to be less than the sum of (i) $250,000,000 plus (ii) thirty percent (30%) of the sum of the Consolidated Net Income of the Borrower (with any consolidated net loss during any fiscal quarter counting as zero) for each fiscal quarter of the Borrower commencing with the fiscal quarter of the Borrower ending June 30, 1997.

  • Consolidated Net Income The consolidated net income of the Borrowers after deduction of all expenses, taxes, and other proper charges, determined in accordance with GAAP.

  • Collection of Income The Custodian shall use reasonable commercial efforts to collect all income and other payments with respect to the Foreign Assets held hereunder to which the Portfolios shall be entitled and shall credit such income, as collected, to the applicable Portfolio. In the event that extraordinary measures are required to collect such income, the Fund and the Custodian shall consult as to such measures and as to the compensation and expenses of the Custodian relating to such measures.

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