Substantial Economic Effect. It is the intent of the Members that the allocations of Profit and Loss under the Agreement have substantial economic effect within the meaning of Code Section 704(b) as interpreted by the Regulations promulgated pursuant thereto. Article VI and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.
Appears in 6 contracts
Samples: Exchange Agreement, Exchange Agreement, Operating Agreement
Substantial Economic Effect. It is the intent of the Members that the allocations of Profit Net Income and Loss Net Losses under the this Agreement have substantial economic effect (or be consistent with the Members' interests in the LLC in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Code Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. This Article VI VII and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Kimco Realty Corp)
Substantial Economic Effect. It is the intent of the Members that the allocations of Profit and Loss under the Agreement have substantial economic effect within the meaning of Code Section 704(b) as interpreted by the Regulations promulgated pursuant thereto. Article VI and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.. ARTICLE VII RIGHTS AND OBLIGATIONS OF THE NON-MANAGING MEMBERS SECTION 7.1
Appears in 1 contract
Samples: Operating Agreement (Central Vermont Public Service Corp)
Substantial Economic Effect. It is the intent of the Members that the allocations of Profit and Loss under the Agreement have substantial economic effect (or be consistent with the Members' interests in the Company in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Code Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. This Article VI V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.. ARTICLE VI
Appears in 1 contract
Samples: Limited Liability Company Operating Agreement (Arbor Realty Trust Inc)