General Allocation. Except as otherwise provided in this ------------------ Section 4.4, items of income, gain, loss and deduction as determined for federal income tax purposes shall be allocated in the same manner as the related items of Profits, Losses, or specially allocated items. Tax credits shall be allocated in accordance with Regulation (S) 1.704-1(b)(4)(ii).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Pacific Aerospace & Electronics Inc), Limited Liability Company Agreement (Pacific Aerospace & Electronics Inc)
General Allocation. Except as otherwise provided in this ------------------ Section 4.44.04, items of income, gain, loss and deduction as determined for federal income tax purposes shall be allocated in the same manner as the related items of Profits, Losses, or specially allocated items. Tax credits shall be allocated in accordance with Regulation (S) §1.704-1(b)(4)(ii).
Appears in 2 contracts
Samples: Operating Agreement (Hallmark Financial Services Inc), Operating Agreement (Hallmark Financial Services Inc)
General Allocation. Except as otherwise provided in this ------------------ Section 4.44.04, items of income, gain, loss and deduction as determined for federal income tax purposes shall be allocated in the same manner as the related items of Profits, Losses, or specially allocated items. Tax credits shall be allocated in accordance with Regulation (S) § 1.704-1(b)(4)(ii).
Appears in 1 contract
Samples: Contribution Agreement (Pennsylvania Real Estate Investment Trust)
General Allocation. Except as otherwise provided in this ------------------ Section 4.4, items of income, gain, loss and deduction as determined for federal income tax purposes shall be allocated in the same manner as the related items of Profits, Losses, or specially allocated items. Tax credits shall be allocated in accordance with Regulation (S) 1.704ss.1.704-1(b)(4)(ii).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Cross Media Marketing Corp)
General Allocation. Except as otherwise provided in this ------------------ Section 4.44.04, items of income, gain, loss and deduction as determined for federal income tax purposes shall be allocated in the same manner as the related items of Profits, Losses, or specially allocated items. Tax credits shall be allocated in accordance with Regulation (S) 1.704ss.1.704-1(b)(4)(ii).
Appears in 1 contract
Samples: Limited Partnership Agreement (Pennsylvania Real Estate Investment Trust)
General Allocation. Except as otherwise provided in this ------------------ Section 4.40, items of income, gain, loss loss, and deduction as determined for federal income tax purposes shall be allocated in the same manner as the related items of Profits, Losses, or specially allocated items. Tax credits shall be allocated in accordance with Regulation § 1.704-1(b)(4)(ii) (S) 26 C.F.R. § 1.704-1(b)(4)(ii)).
Appears in 1 contract
Samples: Limited Partnership Agreement (Commodore Hospitality, Inc)