Partial Year Allocations. In the event that a Partner is admitted to the Partnership during the Partnership’s fiscal year, or all or a portion of a Partner’s Partnership Interest is transferred during the Partnership’s fiscal year, Net Profits and Net Losses shall be allocated to the admitted or transferee Partner in any manner permitted by Code Section 706 or the Treasury Regulations thereunder, as the General Partner shall determine as a Tax Decision.
Appears in 2 contracts
Samples: Limited Partnership Agreement, Limited Partnership Agreement (Universal City Travel Partners)
Partial Year Allocations. In the event that a Partner is admitted to the Partnership during the Partnership’s 's fiscal year, or all or a portion of a Partner’s 's Partnership Interest is transferred during the Partnership’s 's fiscal year, Net Profits and Net Losses shall be allocated to the admitted or transferee Partner in any manner permitted by Code Section 706 or the Treasury Regulations thereunder, as the General Partner shall determine as a Tax Decision.
Appears in 2 contracts
Samples: Limited Partnership Agreement, Limited Partnership Agreement (Universal City Development Partners LTD)
Partial Year Allocations. In the event that a Limited Partner is admitted to the Partnership during the Partnership’s fiscal yearFiscal Year, or all or a portion of a Limited Partner’s Partnership Interest is Units are transferred during the Partnership’s fiscal yearFiscal Year, Net Profits and Net Losses shall be allocated to the admitted or transferee Limited Partner in any manner permitted by Code Section 706 or the Treasury Regulations thereunder, as the General Partner shall determine as in its discretion. Allocations made in this Article IV shall be made to each holder of a Tax DecisionUnit whether or not the holder is a substituted Limited Partner.
Appears in 1 contract
Samples: Limited Partnership Agreement (Lakeview Rehabilitation Group Partners)