Special Allocations and Limitations. (i) In the event a Member unexpectedly receives in any taxable year any adjustments, allocations, or distributions described in Treasury Regulation Section 1.704-1(b)(2) (ii)(d)(4), (5), or (6) which cause or increase an Adjusted Capital Account Deficit of such Mem- ber, items of Company income and gain shall be specially allocated to such Member in such tax- able year (and, if necessary in subsequent taxable years), in an amount and manner sufficient to eliminate, to the extent required by the Treasury Regulations, the Adjusted Capital Account Deficit of such Member as quickly as possible.
Appears in 2 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement
Special Allocations and Limitations. (i1) In the event a Member unexpectedly receives in any taxable year any adjustments, allocations, or distributions described in Treasury Regulation Section 1.704-1(b)(2) (ii)(d)(41(b)(2)(ii)(d)(4), (5), or (6) which cause or increase an Adjusted Capital Account Deficit (as defined in Section 13.1) of such Mem- berMember, items of Company income and gain shall be specially allocated to such Member in such tax- able taxable year (and, if necessary in subsequent taxable years), in an amount and manner sufficient to eliminate, to the extent required by the Treasury Regulations, the Adjusted Capital Account Deficit of such Member as quickly as possible.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (MDC Partners Inc), Limited Liability Company Agreement (MDC Partners Inc)
Special Allocations and Limitations. (i) In the event a Member unexpectedly receives in any taxable year any adjustments, allocations, or distributions described in Treasury Regulation Section 1.704-1(b)(2) (ii)(d)(41.704- 1(b)(2)(ii)(d)(4), (5), or (6) which cause or increase an Adjusted Capital Account Deficit of such Mem- berMember, items of Company income and gain shall be specially allocated to such Member in such tax- able taxable year (and, if necessary in subsequent taxable years), in an amount and manner sufficient to eliminate, to the extent required by the Treasury Regulations, the Adjusted Capital Account Deficit of such Member as quickly as possible.
Appears in 1 contract
Samples: Limited Liability Company Agreement
Special Allocations and Limitations. (i) In the event a Member unexpectedly receives in any taxable year any adjustments, allocations, or distributions described in Treasury Regulation Section 1.704-1(b)(2) (ii)(d)(41(b)(2)(ii)(d)(4), (5), or (6) which cause or increase an Adjusted Capital Account Deficit of such Mem- berMember, items of Company income and gain shall be specially allocated to such Member to the extent of his Membership Interest therein in such tax- able taxable year (and, if necessary in subsequent taxable years), in an amount and manner sufficient to eliminate, to the extent required by the Treasury Regulations, the Adjusted Capital Account Deficit of such Member as quickly as possible.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Envirokare Tech Inc)