Common use of Distributive Shares Clause in Contracts

Distributive Shares. For purposes of Subchapter K of the Code, the distributive shares of the Interest Holders of each item of Company taxable income, gains, losses, deductions or credits for any Fiscal Year shall be in the same proportions as their respective shares of the net income or net loss of the Company allocated to them pursuant to Section 6.1. Notwithstanding the foregoing, to the extent not inconsistent with the allocation of gain provided for in Section 6.1, gain recognized by the Company which represents recapture of depreciation or cost recovery deductions for Federal income tax purposes shall be allocated in the manner provided in Treas. Reg. § 1.1245-1(e) (regardless of whether real property or personal property is involved).

Distributive Shares. For purposes of Subchapter K of the Code, the distributive shares of the Interest Holders of each item of Company taxable income, gains, losses, deductions or credits for any Fiscal Year shall be in the same proportions as their respective shares of the net income or net loss of the Company allocated to them pursuant to Section 6.17.1. Notwithstanding the foregoing, to the extent not inconsistent with the allocation of gain provided for in Section 6.17.1, gain recognized by the Company which represents recapture of depreciation or cost recovery deductions for Federal income tax purposes shall be allocated in the manner provided in Treas. Reg. § 1.1245-1(e) (regardless of whether real property or personal property is involved).

Distributive Shares. For purposes of Subchapter K of the Code, the distributive shares of the Interest Holders of each item of Company taxable income, gains, losses, deductions or credits for any Fiscal Year shall be in the same proportions as their respective shares of the net income or net loss of the Company allocated to them pursuant to Section 6.1. Notwithstanding the foregoing, to the extent not inconsistent with the allocation of gain provided for in Section 6.1, gain recognized by the Company which represents recapture of depreciation or cost recovery deductions for Federal income tax purposes shall be allocated in the manner provided in Treas. Reg. § 1.1245-1(el(e) (regardless of whether real property or personal property is involved).

Distributive Shares. For purposes of Subchapter K of the Code, the distributive shares of the Interest Holders Members of each item of Company taxable income, gains, losses, deductions or credits for any Fiscal Year shall be in the same proportions as their respective shares of the net income profits or net loss of the Company allocated to them pursuant to Section 6.1in accordance with Article VI. Notwithstanding the foregoing, to the extent not inconsistent with the allocation of gain provided for in Section 6.1Article VI, gain recognized by the Company which represents recapture of depreciation or cost recovery deductions for Federal income tax purposes shall be allocated in accordance with the manner provided in provisions of Treas. Reg. § 1.1245-1(e) (regardless of without regard to whether real property or personal property is involved).

Distributive Shares. For purposes of Subchapter K of the Code, the distributive shares sharks of the Interest Holders Members of each item item. of Company taxable income, gains, losses, deductions or credits for any Fiscal Year shall be in the same proportions as their respective shares of the net income or net loss of the Company allocated to them pursuant to Section 6.17.1. Notwithstanding the foregoing, to the extent not inconsistent with the allocation of gain provided for in Section 6.17.1, gain recognized by the Company which represents recapture of depreciation or depreciation, cost recovery or depletion deductions for Federal income tax purposes shall be allocated in accordance with the manner provided in provisions of Treas. Reg. § 1.1245-1(e) (regardless of without regard to whether real property or personal property is involved).

Distributive Shares. For purposes of Subchapter K of the Code, the distributive shares of the Interest Holders of each item of Company taxable income, gains, losses, deductions or credits for any Fiscal Year shall be in the same proportions as their respective shares of the net income or net loss of the Company allocated to them pursuant to Section 6.17.1. Notwithstanding the foregoing, to the extent not inconsistent with the allocation of gain provided for in Section 6.17.1, gain recognized by the Company which represents recapture of depreciation or cost recovery deductions for Federal income tax purposes shall be allocated in the manner provided in Treas. Reg. § 1.1245-1(el(e) (regardless of whether real property or personal property is involved).

Distributive Shares. For purposes of Subchapter K of the Code, the distributive shares of the Interest Holders Members of each item of Company taxable income, gains, losses, deductions or credits for any Fiscal Year shall be in the same proportions as their respective shares of the net income or net loss of the Company allocated to them pursuant to Section 6.16.1 hereof. Notwithstanding the foregoing, to the extent not inconsistent with the allocation of gain provided for in Section 6.1, gain recognized by the Company which represents recapture of depreciation or cost recovery deductions for Federal income tax purposes shall be allocated in accordance with the manner provided in provisions of Treas. Reg. § §1.1245-1(e) (regardless of without regard to whether real property or personal property is involved).