Common use of Tax Capital Accounts; Tax Allocations Clause in Contracts

Tax Capital Accounts; Tax Allocations. (a) For U.S. federal income tax purposes, there shall be established for each Member a single capital account combining such Member’s Capital Commitment Capital Account and GP-Related Capital Account, with such adjustments as the Managing Member determines is appropriate so that such single capital account is maintained in compliance with the principles and requirements of Section 704(b) of the Code and the Regulations thereunder. (b) For federal, state and local income tax purposes only, Company income, gain, loss, deduction or expense (or any item thereof) for each fiscal year shall be allocated to and among the Members in a manner corresponding to the manner in which corresponding items are allocated among the Members pursuant to clause (a) above, provided the Managing Member may in its sole discretion make such allocations for tax purposes as it determines is appropriate so that allocations have substantial economic effect or are in accordance with the interests of the Members, within the meaning of the Code and the Regulations thereunder.

Tax Capital Accounts; Tax Allocations. (a) For U.S. federal Federal income tax purposes, there shall be established for each Member Partner a single capital account combining such MemberPartner’s Capital Commitment Capital Account and GP-Related Capital Account, with such adjustments as the Managing Member General Partner determines is are appropriate so that such single capital account is maintained in compliance with the principles and requirements of Section 704(b) of the Code and the Regulations thereunder. (b) For federalFederal, state State and local income tax purposes only, Company Partnership income, gain, loss, deduction or expense (or any item thereof) for each fiscal year shall be allocated to and among the Members Partners in a manner corresponding to the manner in which corresponding items are allocated among the Members Partners pursuant to clause (a) above, provided the Managing Member General Partner may in its sole discretion make such allocations for tax purposes as it determines is are appropriate so that allocations have substantial economic effect or are in accordance with the interests of the MembersPartners, within the meaning of the Code and the Regulations thereunder.

Tax Capital Accounts; Tax Allocations. (a) For U.S. federal Federal income tax purposes, there shall be established for each Member a single capital account combining such Member’s Capital Commitment Capital Account and GP-Related Capital Account, with such adjustments as the Managing Member determines is appropriate so that such single capital account is maintained in compliance with the principles and requirements of Section 704(b) of the Code and the Regulations thereunder. (b) For federalFederal, state State and local income tax purposes only, Company income, gain, loss, deduction or expense (or any item thereof) for each fiscal year shall be allocated to and among the Members in a manner corresponding to the manner in which corresponding items are allocated among the Members pursuant to clause (a) above, provided the Managing Member may in its sole discretion make such allocations for tax purposes as it determines is appropriate so that allocations have substantial economic effect or are in accordance with the interests of the Members, within the meaning of the Code and the Regulations thereunder.

Tax Capital Accounts; Tax Allocations. (a) For U.S. federal income tax purposes, there shall be established for each Member a single capital account combining such Member’s Capital Commitment Capital Account and GP-Related Capital Account, with such adjustments as the Managing Member determines is appropriate so that such single capital account is maintained in compliance with the principles and requirements of Section 704(b) of the Code and the Regulations thereunder. (b) For federal, state and local income tax purposes only, Company income, gain, loss, deduction or expense (or any item thereof) for each fiscal year shall be allocated to and among the Members in a manner corresponding to the manner in which corresponding items are allocated among the Members pursuant to clause (a) above, provided the Managing Member may in its sole discretion make such allocations for tax purposes as it determines is appropriate so that allocations have substantial economic effect or are in accordance with the interests of the Members, within the meaning of the Code and the Regulations thereunderRegulations.

Tax Capital Accounts; Tax Allocations. (a) For U.S. federal income tax purposes, there shall be established for each Member Partner a single capital account combining such MemberPartner’s Capital Commitment Capital Account and GP-Related Capital Account, with such adjustments as the Managing Member General Partner determines is are appropriate so that such single capital account is maintained in compliance with the principles and requirements of Section 704(b) of the Code and the Treasury Regulations thereunder. (b) For federalFederal, state State and local income tax purposes only, Company Partnership income, gain, loss, deduction or expense (or any item thereof) for each fiscal year shall be allocated to and among the Members Partners in a manner corresponding to the manner in which corresponding items are allocated among the Members Partners pursuant to clause (a) above; provided, provided that the Managing Member General Partner may in its sole discretion make such allocations for tax purposes as it determines is are appropriate so that allocations have substantial economic effect or are in accordance with the interests of the MembersPartners, within the meaning of the Code and the Treasury Regulations thereunder.