Limited Effect and Interpretation. The special rules set forth in Sections 7.2(a), (b), (c), (d), (e) and (f) (the “Regulatory Allocations”) shall be applied only to the extent required by applicable Regulations for the resulting allocations provided for in this Section 7.2, taking into account such Regulatory Allocations, to be respected for U.S. federal income tax purposes. The Regulatory Allocations are intended to comply with the requirements of Regulation Sections 1.704-1(b), 1.704-2 and 1.752-1 through 1.752-5, inclusive, and shall be interpreted and applied consistently therewith.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Phillips 66 Partners Lp), Limited Liability Company Agreement (Phillips 66 Partners Lp), Formation and Contribution Agreement (Phillips 66 Partners Lp)
Limited Effect and Interpretation. The special rules set forth in Sections Section 7.2(a), (b), (c), (d), (e) and (f) (the “Regulatory Allocations”) shall be applied only to the extent required by applicable Regulations for the resulting allocations provided for in this Section 7.2, taking into account such Regulatory Allocations, to be respected for U.S. federal income tax purposes. The Regulatory Allocations are intended to comply with the requirements of Regulation Sections 1.704-1(b), 1.704-2 and 1.752-1 through 1.752-5, inclusive, inclusive and shall be interpreted and applied consistently therewith.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Phillips 66), Limited Liability Company Agreement (Spectra Energy Corp.), Limited Liability Company Agreement (Duke Energy Corp)
Limited Effect and Interpretation. The special rules set forth in Sections 7.2(a), (b), (c), (d), (e) and (f) (the “"Regulatory Allocations”") shall be applied only to the extent required by applicable Regulations for the resulting allocations provided for in this Section 7.2, taking into account such Regulatory Allocations, to be respected for U.S. federal Federal income tax purposes. The Regulatory Allocations are intended to comply with the requirements of Regulation Sections 1.704-1(b), 1.704-2 and 1.752-1 through 1.752-5, inclusive, inclusive and shall be interpreted and applied consistently therewith.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Phillips Petroleum Co), Limited Liability Company Agreement (Duke Energy Field Services LLC)
Limited Effect and Interpretation. The special rules set forth in Sections 7.2(a5.03(c)(i)(A), (bB), (cC), (d), (eD) and (fE) (the “Regulatory Allocations”) shall be applied only to the extent required by applicable Regulations for the resulting allocations provided for in this Section 7.25.03, taking into account such Regulatory Allocations, to be respected for U.S. federal income tax purposes. The Regulatory Allocations are intended to comply with the requirements of Regulation Sections 1.704-1(bl(b), 1.704-2 and 1.752-1 through 1.752-5, inclusive, 5 and shall be interpreted and applied consistently therewith.
Appears in 1 contract
Samples: Limited Liability Company Agreement (NRG Retail LLC)
Limited Effect and Interpretation. The special rules set forth in Sections 7.2(a13.4(a)(i), (bii), (ciii), (d), (eiv) and (fv) (the “"Regulatory Allocations”") shall be applied only to the extent required by applicable Regulations for the resulting allocations provided for in this Section 7.213.4, taking into account such Regulatory Allocations, to be respected for U.S. federal income tax purposes. The Regulatory Allocations are intended to comply with the requirements of Regulation Sections 1.704ss.ss.1.704-1(b), 1.704-2 and 1.752-1 through 1.752-5, inclusive, 5 of the Regulations and shall be interpreted and applied consistently therewith.
Appears in 1 contract
Samples: Operating Agreement (Careinsite Inc)
Limited Effect and Interpretation. The special rules set forth in Sections 7.2(a9.4(a)(i), (bii), (ciii), (d), (eiv) and (fv) (the “"Regulatory Allocations”") shall be applied only to the extent required by applicable Regulations for the resulting allocations provided for in this Section 7.29.4, taking into account such Regulatory Allocations, to be respected for U.S. federal income tax purposes. The Regulatory Allocations are intended to comply with the requirements of Regulation Sections sections 1.704-1(b), 1.704-2 and 1.752-1 through 1.752-5, inclusive, 5 of the Regulations and shall be interpreted and applied consistently therewith.
Appears in 1 contract
Limited Effect and Interpretation. The special rules set forth in Sections 7.2(a6.1(b)(i), (bii), (c), (d), (eiii) and (fiv) (the “"Regulatory Allocations”") shall be applied only to the extent required by applicable Treasury Regulations for the resulting allocations provided for in this Section 7.26.1, taking into account such Regulatory Allocations, to be respected for U.S. federal income tax purposes. The Regulatory Allocations are intended to comply with the requirements of Regulation Treasury Regulations, Sections 1.704-1(b), 1.704-2 and 1.7521-752-1 through 1.752-5, inclusive, 5 and shall be interpreted and applied consistently therewith.
Appears in 1 contract
Limited Effect and Interpretation. The special rules set forth in Sections 7.2(a6.1(b)(i), (b), (c), (d), (eii) and (fiii) (the “"Regulatory Allocations”") shall be applied only to the extent required by applicable Treasury Regulations for the resulting allocations provided for in this Section 7.26.1, taking into account such Regulatory Allocations, to be respected for U.S. federal income tax purposes. The Regulatory Allocations are intended to comply with the requirements of Regulation Treasury Regulations, Sections 1.704-1(b), 1.704-2 and 1.7521-752-1 through 1.752-5, inclusive, 5 and shall be interpreted and applied consistently therewith.
Appears in 1 contract
Limited Effect and Interpretation. The special rules set forth in Sections 7.2(a3.2(a), (b), (c), (d), (e) ), and (f) (the “Regulatory Allocations”"REGULATORY ALLOCATIONS") shall be applied only to the extent required by applicable Regulations for the resulting allocations provided for in this Section 7.23.2, taking into account such Regulatory Allocations, to be respected for U.S. federal Federal income tax purposes. The Regulatory Allocations are intended to comply with the requirements of Regulation Sections 1.704-1(b), 1.704-2 2, and 1.752-1 through 1.752-5, inclusive, and shall be interpreted and applied consistently therewith.
Appears in 1 contract
Limited Effect and Interpretation. The special rules set forth in Sections 7.2(a4.2(c)(i), (bii), (ciii), (div), (ev) and (fvi) (the “Regulatory Allocations”) shall be applied only to the extent required by applicable Regulations for the resulting allocations provided for in this Section 7.24.2, taking into account such Regulatory Allocations, to be respected for U.S. federal income tax purposes. The Regulatory Allocations are intended to comply with the requirements of Regulation Sections 1.704-1(b), 1.704-2 and 1.752-1 through 1.752-5, inclusive, 5 and shall be interpreted and applied consistently therewith.
Appears in 1 contract
Limited Effect and Interpretation. The special rules set forth in Sections 7.2(a13.5(a)(i), (bii), (ciii), (d), (eiv) and (fv) (the “Regulatory Allocations”) shall be applied only to the extent required by applicable Regulations for the resulting allocations provided for in this Section 7.213.5, taking into account such Regulatory Allocations, to be respected for U.S. federal income tax purposes. The Regulatory Allocations are intended to comply with the requirements of Regulation Sections sections 1.704-1(b), 1.704-2 and 1.752-1 through 1.752-5, inclusive, 5 of the Regulations and shall be interpreted and applied consistently therewith.
Appears in 1 contract
Samples: Operating Agreement (Bluefly Inc)
Limited Effect and Interpretation. The special rules set forth in Sections 7.2(a9(c)(i), (bii), (ciii), (d), (eiv) and (fv) hereof (the “"Regulatory Allocations”") shall be applied only to the extent required by applicable Regulations for the resulting allocations provided for in this Section 7.29(c), taking into account such Regulatory Allocations, to be respected for U.S. federal income tax purposes. The Regulatory Allocations are intended to comply with the requirements of Regulation Sections 1.704-1(b), 1.704-2 and 1.752-1 through 1.752-5, inclusive, 5 of the Regulations and shall be interpreted and applied consistently therewith.
Appears in 1 contract
Samples: Limited Liability Company Operating Agreement (Key Components Finance Corp)