Intention. The special allocations in this Section 6.5 are intended to comply with certain requirements of the Treasury Regulations and will be interpreted consistently. It is the intent of the Members that any special allocation pursuant to this Section 6.5will be offset with other special allocations pursuant to this Section 6.5. Accordingly, special allocations of Fund income, gain, loss or deduction will be made in such manner so that, in the reasonable determination of the Manager, taking into account likely future allocations under this Section 6.5, after those allocations are made, each Member's Capital Account is, to the extent possible, equal to the Capital Account it would have been were this Section 6.5 not part of this Agreement.
Appears in 4 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement, Limited Liability Company Agreement
Intention. The special allocations in this Section 6.5 6.3 are intended to comply with certain requirements of the Treasury Regulations and will shall be interpreted consistentlyconsistently therewith. It is the intent of the Members that any special allocation pursuant to this Section 6.5will 6.3 shall be offset with other special allocations pursuant to this Section 6.56.3. Accordingly, special allocations of Fund income, gain, loss or deduction will shall be made in such manner so that, in the reasonable determination of the Manager, taking into account likely future allocations under this Section 6.56.3, after those such allocations are made, each Member's ’s Capital Account is, to the extent possible, equal to what the Capital Account it would have been were this Section 6.5 6.3 not part of this Agreement.Agreement.
Appears in 2 contracts
Samples: Limited Liability Company Operating Agreement, Limited Liability Company Operating Agreement
Intention. The special allocations in this Section 6.5 are intended to comply with certain requirements of the Treasury Regulations and will be interpreted consistently. It is the intent of the Members that any special allocation pursuant to this Section 6.5will 6.5 will be offset with other special allocations pursuant to this Section 6.5. Accordingly, special allocations of Fund income, gain, loss or deduction will be made in such manner so that, in the reasonable determination of the Manager, taking into account likely future allocations under this Section 6.5, after those allocations are made, each Member's Capital Account is, to the extent possible, equal to the Capital Account it would have been were this Section 6.5 not part of this the Agreement.
Appears in 2 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement
Intention. The special allocations in this Section 6.5 6.3 are intended to comply with certain requirements of the Treasury Regulations and will shall be interpreted consistentlyconsistently therewith. It is the intent of the Members that any special allocation pursuant to this Section 6.5will 6.3 shall be offset with other special allocations pursuant to this Section 6.56.3. Accordingly, special allocations of Fund Company income, gain, loss or deduction will shall be made in such manner so that, in the reasonable determination of the ManagerManager or Managing Member, taking into account likely future allocations under this Section 6.56.3, after those such allocations are made, each Member's ’s Capital Account is, to the extent possible, equal to the Capital Account it would have been were this where Section 6.5 6.3 not part of this Agreement.
Appears in 1 contract
Samples: Operating Agreement
Intention. The special allocations in this Section 6.5 6.3 are intended to comply with certain requirements of the Treasury Regulations and will shall be interpreted consistentlyconsistently therewith. It is the intent of the Members that any special allocation pursuant to this Section 6.5will 6.3 shall be offset with other special allocations pursuant to this Section 6.56.3. Accordingly, special allocations of Fund income, gain, loss or deduction will shall be made in such manner so that, in the reasonable determination of the Manager, taking into account likely future allocations under this Section 6.56.3, after those such allocations are made, each Member's ’s Capital Account is, to the extent possible, equal to what the Capital Account it would have been were this Section 6.5 6.3 not part of this Agreement.
Appears in 1 contract
Intention. The special allocations in this Section 6.5 5.05 are intended to comply with certain requirements of the Treasury Regulations and will be interpreted consistently. It is the intent of the Members that any special allocation pursuant to this Section 6.5will will be offset with other special allocations pursuant to this Section 6.5Section. Accordingly, special allocations of Fund Company income, gain, loss or deduction will be made in such manner so that, in the reasonable determination of the Manager, taking into account likely future allocations under this Section 6.5Section, after those allocations are made, each Member's ’s Capital Account is, to the extent possible, equal to the Capital Account it would have been were this Section 6.5 not part of this Agreement.
Appears in 1 contract
Samples: Company Agreement
Intention. The special allocations in this Section 6.5 6.3 are intended to comply with certain requirements of the Treasury Regulations and will shall be interpreted consistentlyconsistently therewith. It is the intent of the Members that any special allocation pursuant to this Section 6.5will 6.3 shall be offset with other special allocations pursuant to this Section 6.56.3. Accordingly, special allocations of Fund Company income, gain, loss or deduction will shall be made in such manner so that, in the reasonable determination of the ManagerManaging Member, taking into account likely future allocations under this Section 6.56.3, after those such allocations are made, each Member's ’s Capital Account is, to the extent possible, equal to the Capital Account it would have been were this Section 6.5 6.3 not part of this Agreement.
Appears in 1 contract
Samples: Operating Agreement
Intention. The special allocations in this Section 6.5 are intended to comply with certain requirements of the Treasury Regulations and will be interpreted consistently. It is the intent of the Members that any special allocation pursuant to this Section 6.5will 6.5 will be offset with other special allocations pursuant to this Section 6.5. Accordingly, special allocations of Fund income, gain, loss or deduction will be made in such manner so that, in the reasonable determination of the Manager, taking into account likely future allocations under this Section 6.5, after those allocations are made, each Member's Capital Account is, to the extent possible, equal to the Capital Account it would have been were this Section 6.5 not part of this Agreement.
Appears in 1 contract
Samples: Limited Liability Company Agreement