Special Fee Allocation. If any fee or other amount payable to a Member is determined for tax purposes to be a payment to such Member of a distributive share of Company income or gain (rather than being a fee or expenditure in the nature of an amount payable to a person who is not a Member or other than in such person's capacity as a Member), then such amount shall be treated (for tax purposes and for purposes of determining Capital Accounts) as an allocation of gross income to such Member in the year such amount is accrued, and a distribution in the year such amount is paid. However, the priority of payment of any such item shall be unaffected by such treatment.
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Samples: Operating Agreement (Taylor Investment Corp /Mn/), Operating Agreement (Taylor Investment Corp /Mn/)
Special Fee Allocation. If any fee or other amount payable to a Member is determined for income-tax purposes to be a payment to such Member of a distributive share of Company income or gain (rather than being a fee or expenditure in the nature of an amount payable to a person Person who is not a Member or other than in such personPerson's capacity as a Member), then such amount shall be treated (for income-tax purposes and for purposes of determining Capital Accounts) as an allocation of gross income to such Member in the year such amount is accrued, and a distribution Distribution in the year such amount is paid. However, the The priority of payment of any such item item, however, shall be unaffected by such treatment.
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Special Fee Allocation. If any fee or other amount payable to a Member is determined for income tax purposes to be a payment to such Member of a distributive share of Company income or gain (rather than being a fee or expenditure in the nature of an amount payable to a person Person who is not a Member or other than in such personPerson's capacity as a Member), then such amount shall be treated (for income tax purposes and for purposes of determining Capital Accounts) as an allocation of gross income to such Member in the year such amount is accrued, and a distribution Distribution in the year such amount is paid. However, the priority of payment of any such item shall be unaffected by such treatment.
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Samples: Limited Liability Company Agreement (WPT Enterprises Inc)
Special Fee Allocation. If any fee or other amount payable to a Member is determined for tax purposes to be a payment to such Member of a distributive share of Company income or gain (rather than being a fee or expenditure in the nature of an amount payable to a person Person who is not a Member or other than in such personPerson's capacity as a Member), then such amount shall be treated (for tax purposes and for purposes of determining Capital Accounts) as an allocation of gross income to such Member in the year such amount is accrued, and a distribution in the year such amount is paid. However, the priority of payment of any such item shall be unaffected by such treatment.
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Samples: Member Control Agreement (Taylor Investment Corp /Mn/)