Profit and Loss. Subject to Section 5.1(d) hereof, Profit and Loss occurring on any day during the Fiscal Year shall be allocated to the Holders' Book Capital Accounts at the end of such day in proportion to the Holders' respective Book Capital Account balances at the commencement of such day.
Profit and Loss. Subject to any other provisions of this Agreement, the net profits and losses of the Partnership, for both accounting and tax purposes, will accrue to and be borne by the Partners in proportion to the Partners Capital Contributions inclusive of any Additional Capital Contributions (hereinafter referred to as the “Profit and Loss Distribution”).
Profit and Loss. 4.1 Definitions of Net Profit and Net Loss. Profits and losses for any Operations Period, as hereinafter defined, will be computed in the same manner as the Partnership reports its income for Federal income tax purposes, except that (i) income of the Partnership that is exempt from tax and expenses that are not deductible for tax purposes under the Code will be included in the computation and (ii) unrealized gain or loss will be taken into account as provided herein. The principles of Treasury Regulation Section 1.704-1(b)(4)(i) will be applied, when necessary, to prevent duplication or omission of Capital Account adjustments, including without limitation, those arising from deemed sales as provided in this Agreement.
Profit and Loss. 7.6.1 You further understand that a payment will pass between us equal to the difference in value expressed in the Base Currency between the opening price of all Positions and their Closing Prices. If you make a profit, we must pay a sum to you equal to that profit. If you make a Ioss you must pay to us a sum equal to that loss.
Profit and Loss. All items of income, gain, loss and deduction of the Company for financial accounting and tax purposes shall be allocated 100% to each Member.
Profit and Loss. 6.1. The percentages of Partnership Rights and Partnership Interest of each of the Partners shall be as follows:
6.2. Except as provided in Section 7.3. of this Agreement, for purposes of Sections 702 and 704 of the Internal Revenue Code of 1954, or the corresponding provisions of any future federal internal revenue law, or any similar tax law of any state or jurisdiction, the determination of each Partner's distributive share of all items of income, gain, loss, deduction, credit or allowance of the Partnership for any period or year shall be made in accordance with, and in proportion to, such Partner's percentage of Partnership Interest as it may then exist.
Profit and Loss. The net profits of the partnership shall be divided equally between the partners and the net losses shall be borne equally by them. A separate income account shall be maintained for each partner. Partnership profits and losses shall be charged or credited to the separate income account of each partner. If a partner has no credit balance in his income account, losses shall be charged to his capital account.
Profit and Loss. (a) The Profit and Loss of the Company for purposes of determining allocations to the Capital Accounts of the Members shall be determined in the same manner as the determination of the Company’s taxable income pursuant to Section 703(a) of the Code, except that (i) items that are required by Section 703(a)(1) of the Code to be separately stated shall be included; (ii) items of income that are exempt from inclusion in gross income for Federal income tax purposes shall be treated as Book income, and related deductions that are disallowed under Section 265 of the Code shall be treated as Book deductions; (iii) Section 705(a)(2)(B) Expenditures shall be treated as deductions; (iv) items of gain, loss, depreciation, amortization, or depletion that would be computed for Federal income tax purposes by reference to the Tax Basis of an item of Company property shall be determined by reference to the Book Value of such item of property; (v) the effects of upward and downward revaluations of Company property pursuant to Section 2.02 of this Appendix shall be treated as gain or loss respectively from the sale of such property; and (vi) any items that are specially allocated pursuant to Section 3.04 of this Appendix shall not be taken into account in computing Profit or Loss, but the amounts of those items are to be determined by applying rules comparable to those provided in subparagraphs (i) through (v) above, and clause (b) below.
(b) In the event that the Book Value of any item of Company property differs from its Tax Basis, the amount of Book depreciation, depletion, or amortization for a period with respect to such property shall be computed so as to bear the same relationship to the Book Value of such property as the depreciation, depletion, or amortization computed for tax purposes with respect to such property for such period bears to the Tax Basis of such property. If the Tax Basis of such property is zero, the Book depreciation, depletion, or amortization with respect to such property shall be computed by using a method consistent with the method that would be used for tax purposes if the Tax Basis of such property were greater than zero.
(c) Allocations to the Capital Accounts of the Members shall be based on the Profit or Loss of the Company as determined pursuant to this Section 3.01. Such allocations shall be made as provided in the Agreement except to the extent modified by the provisions of this Article 3.
Profit and Loss. The Membership Interest of the Member in the profits and losses of Company shall be one hundred percent (100%).
Profit and Loss. All profit and loss of the Company and all assets and liabilities of the Company shall, solely for state and federal income tax purposes, be treated as the profits, losses, assets and liabilities of the Member pursuant to Treasury Regulations Section 301.7701-3, but for no other purpose (including, without limitation, limited liability protection for the Member from Company liabilities).
