Elections and Limitations. The allocations required by this Section 5.8 are solely for purposes of federal, state and local income taxes and shall not affect the allocation of Net Profits or Net Losses among Partners or any Partner’s Capital Account. All tax allocations required by this Section 5.8 shall be made using the so called “traditional method” described in Regulations Section 1.704-3(b).
Appears in 4 contracts
Samples: Limited Partnership Agreement (Premier, Inc.), Limited Partnership Agreement (Premier, Inc.), Limited Partnership Agreement (Premier, Inc.)
Elections and Limitations. The allocations required by this Section 5.8 5.7 are solely for purposes of U.S. federal, state and local income taxes and shall not affect the allocation of Net Profits or Net Losses among as between Limited Partners or any Limited Partner’s Capital Account. All tax allocations required by this Section 5.8 5.7 shall be made using the so called “traditional method” described in Regulations Section any method permitted by Regulation 1.704-3(b)3 as determined by the General Partner, with the advice of the Partnership’s auditors or tax counsel.
Appears in 3 contracts
Samples: Agreement of Exempted Limited Partnership (Taylor Morrison Home Corp), Agreement of Exempted Limited Partnership (Taylor Morrison Home Corp), Agreement of Exempted Limited Partnership
Elections and Limitations. The allocations required by this Section 5.8 are solely for purposes of federal, state and local income taxes and shall not affect the allocation of Net Profits or Net Losses among Partners as between Members or any PartnerMember’s Capital Account. All tax allocations required by this Section 5.8 shall be made using the so called “traditional method” that is described in the Regulations Section 1.704-3(b)3.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Jefferies Financial Group Inc.), Purchase and Sale Agreement (Leucadia National Corp)
Elections and Limitations. The allocations required by this Section 5.8 5.2(d) are solely for purposes of federal, state and local income taxes and shall not affect either the allocation of Net Profits Income or Net Losses among Partners Loss as between Members or any PartnerMember’s Capital Account. All tax allocations required by this Section 5.8 5.2(d) shall be made using any method determined appropriate by the so called “traditional method” described in Regulations Section 1.704-3(b)Managing Member.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Norcraft Companies, Inc.), Limited Liability Company Agreement (Norcraft Companies, Inc.)
Elections and Limitations. The allocations required by this Section 5.8 are solely for purposes of federal, state and local income taxes and shall not affect the allocation of Net Profits or Net Losses among Partners as between Members or any PartnerMember’s Capital Account. All tax allocations required by this Section 5.8 shall be made using the so called “traditional method” any method that is described in Regulations the Section 1.704-3(b)3 Regulations, as decided by the Board of Managers.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Leucadia National Corp), Membership Interest Purchase Agreement (National Beef Packing Co LLC)
Elections and Limitations. The allocations required by this Section 5.8 are solely for purposes of federal, state and local income taxes and shall not affect the allocation of Net Profits or Net Losses among Partners as between Members or any PartnerMember’s Capital Account. All tax allocations required by this Section 5.8 shall be made using the so called “traditional method” described in Regulations Section Regulation 1.704-3(b).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (National Beef, Inc.), Limited Liability Company Agreement (National Beef, Inc.)
Elections and Limitations. The allocations required by this Section 5.8 5.7 are solely for purposes of federal, state and local income taxes and shall not affect the allocation of Net Profits or Net Losses among Partners as between Members or any PartnerMember’s Capital Account. All tax allocations with respect to property acquired or owned as of the date hereof and required by this Section 5.8 5.7 shall be made using the so so-called “traditional methodmethod with curative allocations” described in Regulations Section Regulation 1.704-3(b3(c).
Appears in 1 contract
Samples: Limited Liability Company Agreement (National Commerce Corp)
Elections and Limitations. The allocations required by this Section 5.8 5.11 are solely for purposes of U.S. federal, state and local income taxes and shall not affect the allocation of Net Profits or Net Losses among Partners as between Members or any PartnerMember’s Capital Account. All tax allocations required by this Section 5.8 shall be made using the so called “traditional method” described in Regulations Section 1.704-3(b).
Appears in 1 contract
Samples: Limited Liability Company Agreement (New York REIT, Inc.)
Elections and Limitations. The allocations required by this Section 5.8 are solely for purposes of federal, state and local income taxes and shall not affect the allocation of Net Profits or Net Losses among Partners as between Members or any Partner’s Member's Capital Account. All tax allocations required by this Section 5.8 shall be made using the so called “"traditional method” " that is described in the Regulations Section 1.704-3(b)3.
Appears in 1 contract
Samples: Limited Liability Company Agreement (U. S. Premium Beef, LLC)
