Income Tax Allocations. (a) To the maximum extent possible and except as otherwise provided in this Section 6.6, all items of income, gain, loss and deduction for Federal income tax purposes shall be allocated in the same manner as the corresponding item of income, gain, loss and deduction for Capital Account purposes is allocated.
Appears in 6 contracts
Samples: Limited Liability Company Agreement (Quintana Maritime LTD), Limited Liability Company Agreement (Quintana Maritime LTD), Limited Liability Company Agreement (Quintana Maritime LTD)
Income Tax Allocations. (a) To the maximum extent possible and except as otherwise provided in this Section 6.6, all All items of income, gain, loss and deduction for Federal U.S. federal income tax purposes shall be allocated in the same manner as the corresponding item of incomeis allocated pursuant to Sections 6.2(a) or 6.2(b), gain, loss and deduction for Capital Account purposes is allocatedexcept as otherwise provided in this Sections 6.3.
Appears in 4 contracts
Samples: Membership Interest Purchase Agreement (LMP Automotive Holdings, Inc.), Membership Interest Purchase Agreement (LMP Automotive Holdings, Inc.), Membership Interest Purchase Agreement (LMP Automotive Holdings, Inc.)
Income Tax Allocations. (a) To the maximum extent possible and except Except as otherwise provided in this Section 6.66.3, all items of income, gain, loss and deduction for Federal income tax purposes shall be allocated in the same manner as the corresponding each item of income, gain, loss and deduction of the Company for federal income tax purposes shall be allocated, to the maximum extent possible, among the Members in the same manner as the corresponding items (if any) are allocated for purposes of maintaining Capital Account purposes is allocatedAccounts under Section 6.2.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Magnum Hunter Resources Corp), Limited Liability Company Agreement (Magnum Hunter Resources Corp), Limited Liability Company Agreement (USW Financing Corp.)
Income Tax Allocations. (a) To the maximum extent possible and except as otherwise provided in this Section 6.6, all All items of income, gain, loss and deduction for Federal U.S. federal income tax purposes shall be allocated in the same manner as the corresponding item of incomeis allocated pursuant to Section 6.2 or Section 6.3, gain, loss and deduction for Capital Account purposes is allocatedexcept as otherwise provided in this Section 6.4.
Appears in 3 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement (Robertson Corbin J Jr), Limited Liability Company Agreement (Antero Resources Midstream Management LLC)
Income Tax Allocations. (a) To the maximum extent possible and except as otherwise provided in this Section 6.6, all All items of income, gain, loss and deduction for Federal income tax purposes shall be allocated in the same manner as the corresponding item of income, gain, loss Profits and deduction for Capital Account purposes Losses is allocated, except as otherwise provided in this Section 6.6.
Appears in 2 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement (Quintana Maritime LTD)
Income Tax Allocations. (a) To the maximum extent possible and except as otherwise provided in this Section 6.6, all All items of income, gain, loss and deduction for Federal U.S. federal income tax purposes shall be allocated in the same manner as the corresponding item of incomeis allocated pursuant to Section 5.2 or Section 5.3, gain, loss and deduction for Capital Account purposes is allocatedexcept as otherwise provided in this Section 5.4.
Appears in 2 contracts
Samples: GPM Contribution Agreement (ARKO Corp.), GPM Contribution Agreement (GPM Petroleum LP)
Income Tax Allocations. (a) To the maximum extent possible and except as otherwise provided in this Section 6.6, all All items of income, gain, loss and deduction for Federal income tax purposes shall be allocated in the same manner as the corresponding item of income, gain, loss Profits and deduction for Capital Account purposes Losses is allocated, except as otherwise provided in this Section 5.6.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Laredo Oil, Inc.)
Income Tax Allocations. (a) To the maximum extent possible and except Except as otherwise provided in this Section 6.65.6, all items of income, gain, loss and deduction for Federal federal income tax purposes shall be allocated in the same manner as the corresponding item of income, gain, loss and deduction for Capital Account purposes is allocated, pursuant to Section 5.3, Section 5.4 and Section 5.5.
Appears in 1 contract
Samples: Limited Liability Company Agreement (AleAnna Energy, LLC)
Income Tax Allocations. (a) To the maximum extent possible and except as otherwise provided in this Section 6.6, all All items of income, gain, loss and deduction for Federal federal income tax purposes shall be allocated in the same manner as the corresponding item of income, gain, loss Profits and deduction for Capital Account purposes Losses is allocated, except as otherwise provided in this Section 6.03.
Appears in 1 contract
Samples: Pattern Energy Group Inc.
Income Tax Allocations. (a) To the maximum extent possible and except as otherwise provided in this Section 6.6, all All items of income, gain, loss and deduction for Federal income tax purposes shall be allocated in the same manner as the corresponding item of income, gain, loss Profits and deduction for Capital Account purposes Losses is allocated, except as otherwise provided in this Section 5.05.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Eagle Rock Energy Partners L P)
Income Tax Allocations. (a) To the maximum extent possible and except as otherwise provided in this Section 6.6, all All items of income, gain, loss and deduction for Federal income tax purposes shall be allocated in the same manner as the corresponding item of income, gain, loss Profits and deduction for Capital Account purposes Losses is allocated, except as otherwise provided in this Section 6.5.
Appears in 1 contract
Samples: Limited Liability Company Agreement
Income Tax Allocations. (a) To the maximum extent possible and except Except as otherwise provided in this Section 6.65.2, all items of income, gain, loss and deduction for Federal income tax purposes shall be allocated in the same manner as the corresponding each item of income, gain, loss and deduction of the Company for federal income tax purposes shall be allocated, to the maximum extent possible, among the Members in the same manner as the corresponding items (if any) are allocated for purposes of maintaining Capital Account purposes is allocatedAccounts under Section 5.1.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Hi-Crush Partners LP)
Income Tax Allocations. (a) To the maximum extent possible and except as otherwise provided in this Section 6.6, all All items of income, gain, loss and deduction for Federal federal income tax purposes shall be allocated in the same manner as the corresponding item of income, gain, loss Profits and deduction for Capital Account purposes Losses is allocated, except as provided in Section 5.4(b).
Appears in 1 contract
Income Tax Allocations. (a) To the maximum extent possible and except as otherwise provided in this Section 6.6, all All items of income, gain, loss and deduction for Federal federal income tax purposes shall be allocated in the same manner as the corresponding item of income, gain, loss Profits and deduction for Capital Account purposes Losses is allocated, except as otherwise provided in this Section 6.03.
Appears in 1 contract
Samples: Pattern Energy Group Inc.
