Other Allocations Rules. (a) In the event additional Partners are admitted to the Partnership on different dates during any fiscal year, or their interests in the Partnership otherwise vary during the year, the Profits (or Losses) may be allocated to the Partners in accordance with Section 706, of the Code, or rules comparable to those allowed by Section 706 of the Code, using any convention permitted by law and selected by the General Partner.
(b) For purposes of determining the Profits, Losses or any other items allocable to any period, Profits, Losses and any such other items shall be determined on a daily, monthly, or other basis, as determined by the General Partner using any permissible method under Section 706 of the Code and the Regulations thereunder.
(c) Except as otherwise provided in this Agreement, all items of Partnership income, gain, loss, deduction and any other allocations not otherwise provided for shall be divided among the Partners in the same proportions as they share Profits or Losses, as the case may be, for the year.
Other Allocations Rules. (a) For purposes of determining the Net Profits, Net Losses, or any other items allocable to any period, Net Profits, Net Losses and any other items, shall be determined on a daily, monthly, or other basis, as determined by the Members using any permissible method under Code Section 706 and the Regulations thereunder.
(b) Except as otherwise provided in this Agreement, all items of Company income, gain, loss, and deduction and any other allocations not otherwise provided for shall be divided among the Members in the same proportions as they share Net Profits or Net Losses, as the case may be, for the year.
(c) The Members are aware of the income tax consequences of the allocations made by this Article XII and hereby agree to be bound by the provisions of this Article XII in reporting their share of Company income and loss for income tax purposes.
Other Allocations Rules. (a) For purposes of determining the Profits, Losses or any other items allocable to any period, Profits, Losses, and any such other items shall be determined on a daily, monthly, or other basis, as determined by the Managing Member using any permissible method under Code Section 706 and the Regulations thereunder.
(b) Except as otherwise provided in this Agreement, all items of Company income, gain, loss, and deduction for a Fiscal Year shall, for federal and state income tax purposes, be divided among the Members in the same proportions as they share Profits or Losses, as the case may be, for such Fiscal Year. The Members are aware of the income tax consequences of the allocations made by this Article 6 and hereby agree to be bound by the provisions of this Article 6 in reporting their shares of Company income and loss for income tax purposes.
(c) Solely for purposes of determining the Member’s proportionate share of the “excess nonrecourse liabilities” of the Company within the meaning of Regulations Section 1.752-3(a)(3), the Member’s interests in Company profits are in accordance with their percentage Interests.
(d) To the extent permitted by Section 1.704-2(h)(3) of the Regulations, the Members shall treat distributions of Net Cash as not having been made from the proceeds of a Nonrecourse Liability or a Partner Nonrecourse Debt.
Other Allocations Rules. 3.4.1 The Partners are aware of the income tax consequences of the allocations made by this Article III and hereby agree to be bound by the provisions of this Article III in reporting their shares of Partnership income and loss for income tax purposes.
3.4.2 For purposes of determining the Profits, Losses, or any other items allocable to any period, Profits, Losses, and any such other items shall be determined on a daily, monthly, or other basis, as determined by the General Partner using any permissible method under Code Section 706 and the Treasury Regulations thereunder.
Other Allocations Rules. (a) For purposes of determining the Profits, Losses, or any other items allocable to any period, Profits, Losses, and any such other items shall be determined on a daily, monthly or other basis, as determined by the General Partner using any permissible method under Code Section 706 and the Regulations thereunder.
(b) Except as otherwise provided in this Agreement, all items of Partnership income, gain, loss, deductions, and any other allocations not otherwise provided for shall be divided among the Partners in the same proportions as they share Profits or Losses, as the case may be, for the year.
(c) The Partners are aware of the income tax consequences of the allocations made by this Exhibit B and hereby agree to be bound by the provisions of this Exhibit B in reporting their shares of Partnership income and loss for income tax purposes.
Other Allocations Rules. (i) For purposes of determining the Profits, Losses or any other items allocable to any period, Profits, Losses and any such other items shall be determined on a daily, monthly, or other basis, as determined by the Board using any permissible method under Code Section 706 and the Treasury Regulations thereunder.
(ii) Except as otherwise provided in this Exhibit C-1, all items of Company income, gain, loss, deduction, credit and any other allocations for any fiscal year or other period not otherwise provided for shall be divided among the Members in the same proportions as they share Profits or Losses, as the case may be, for such year or other period.
(iii) The Members are aware of the income tax consequences of the allocations made pursuant to this Exhibit C-1 and hereby agree to be bound by the provisions of this Exhibit C- 1 in reporting their shares of Company income and loss for income tax purposes.
(iv) Solely for purposes of determining a Member's proportionate share of the "excess nonrecourse liabilities" of the Company within the meaning of Treasury Regulations Section 1.752-3(a)(3), the Members' interests in Company profits are in proportion to their Ownership Percentages.
(v) To the extent permitted by Section 1.704- 2(h)(3) of the Treasury Regulations, the Board shall endeavor to treat distributions as having been made from the proceeds of a Nonrecourse Liability or a Member Nonrecourse Debt only to the extent that such distributions would cause or increase an Adjusted Capital Account Deficit for any Member.
(vi) All allocations of income, gain, loss, deduction and credits with respect to periods ending prior to the Effective Date ("Prior Allocations") shall be allocated to the Owners as set forth in the Agreement prior to its amendment by the Purchase Agreement (including this Exhibit C-1). Prior Allocations shall not be taken into account as adjustments to the Capital Accounts of the Owners on or after the Effective Date.
Other Allocations Rules. 17 4.8 Tax Matters Member.................................................. 18 ARTICLE 5
Other Allocations Rules. (a) Generally, all Profits and Losses allocated to the Limited Partners shall be allocated among them in proportion to their Capital Accounts. In the event more than one Person is a General Partner, Profits and Losses allocated to the General Partners shall be divided among them as they may agree.
(b) For purposes of determining the Profits, Losses, or any other items allocable to any period, Profits, Losses, and any such other items shall be determined on a daily, monthly, or other basis, as determined by the General Partner using any permissible method under Code Section 706 and the Regulations.
(c) Except as otherwise provided in this Agreement, all items of Partnership income, gain, loss, deduction, and any other allocations not otherwise provided for shall be divided among the Partners in the same proportions as they share Profits or Losses, as the case may be, for the year.
(d) The Partners are aware of the income tax consequences of the allocations made by this Article IV and hereby agree to be bound by the provisions of this Article IV in reporting their shares of Partnership Profits and Losses for federal and state income tax purposes.
(e) For purposes of determining a Partner’s proportionate share of the “excess nonrecourse liabilities” of the Partnership within the meaning of the Regulations, the Partners’ interests in Partnership Profits shall be in proportion to their Partnership Interests.
Other Allocations Rules. Although it is intended that paragraph 4(a) be the general rule for allocations of book and tax income or loss, such allocations shall be adjusted or modified in any given instance to the extent necessary to comply with Section 704(b) and (c) of the Internal Revenue Code of 1986, as amended (the "Code") and the Treasury Regulations promulgated thereunder. For purpose of determining the profits, losses, or any other items allocable to any period, profits, losses, and any such other items shall be determined on a daily, monthly, or other basis using any permissible method under Code Section 706 and the Treasury Regulations promulgated thereunder; provided, however, that gain or loss from a sale or other taxable disposition of Company property shall be allocable to the period which includes the date that the Sale or other taxable disposition occurred.
Other Allocations Rules. (a) For purposes of determining the Profits, Losses or any other items allocable to any period, Profits, Losses and any such other items shall be determined on a daily, monthly or other basis, as determined by the Management Committee using any permissible method under Code Section 706 and the Regulations thereunder.
(b) Except as otherwise provided in Section 4.6 with respect to allocations pursuant to Code Section 704(c), for federal income tax purposes, all allocations of Partnership income, gain, loss or deduction shall be made in a manner that is consistent with the allocation of Profits and Losses pursuant to this Article 4. The Partners are aware of the income tax consequences of the allocations of this Article 4 and hereby agree to be bound by the provisions of this Article 4 in reporting their allocable shares of Partnership income and loss for income tax purposes.
(c) Solely for purposes of determining a Partner's proportionate share of the "excess nonrecourse liabilities" of the Partnership within the meaning of Regulations Section 1.752-3(a)(3), the Partners' interests in Partnership profits shall be equal to their respective Partnership Interests.
