Common use of General Tax Allocations Clause in Contracts

General Tax Allocations. As of the end of each fiscal year, and after giving effect to the special tax allocations set forth in Section 6.1(b), Net Profits and Net Losses shall be allocated among the Partners for Capital Account purposes as well as federal income tax purposes as follows: (i) Net Profits shall first be allocated to the Partners in the same amount as Net Losses were allocated to such Persons pursuant to Section 6.1(a)(ii) hereof until the cumulative Net Profits allocated pursuant to this Section 6.l(a)(i) are equal to the total get Losses allocated to such Persons for all prior periods and, thereafter, Net Profits shall be allocated to the Partners in accordance with their Participating Percentages with respect to such fiscal year; and (ii) Net Losses shall first be allocated to the Partners in accordance with their Participating Percentages; provided, however, that any losses in excess of the losses allowable to General Partner pursuant to the Treasury Regulations promulgated under Code Section 704(b) shall be allocated to Universal; provided, however, the General Partner shall have the right exercisable in its sole and absolute discretion to amend this Partnership Agreement from time to time to reflect the imposition on the General Partner (but not on Universal) of a limited deficit Capital Account restoration obligation within the meaning of Treasury Regulation ss.1.704-1(b)(2)(ii)(c).

General Tax Allocations. As of the end of each fiscal year, and after giving effect to the special tax allocations set forth in Section 6.1(b), Net Profits and Net Losses shall be allocated among the Partners for Capital Account purposes as well as federal income tax purposes as follows: (i) Net Profits shall first be allocated to the Partners in the same amount as Net Losses were allocated to such Persons pursuant to Section 6.1(a)(iiSection 6.1 (a)(ii) hereof until the cumulative Net Profits allocated pursuant to this Section 6.l(a)(i) are equal to the total get Losses allocated to such Persons for all prior periods and, thereafter, Net Profits shall be allocated to the Partners in accordance with their Participating Percentages with respect to such fiscal year; and (ii) Net Losses shall first be allocated to the Partners in accordance with their Participating Percentages; provided, however, that any losses in excess of the losses allowable to General Partner pursuant to the Treasury Regulations promulgated under Code Section 704(b) shall be allocated to Universal; provided, however, the General Partner shall have the right exercisable in its sole and absolute discretion to amend this Partnership Agreement from time to time to reflect the imposition on the General Partner (but not on Universal) of a limited deficit Capital Account restoration obligation within the meaning of Treasury Regulation ss.1.704-1(b)(2)(ii)(c).