Tax Credits and Similar Items. Any tax credits or similar items not allocable pursuant to Sections 4.2.1 through 4.2.5 shall be allocated to the Interest Holders in proportion to their respective Percentages. Notwithstanding the preceding sentence, Company expenditures that give rise to tax credits attributable to such expenditures shall be allocated in accordance with Regulation Section 1.704-1(b)(4)(ii).
Appears in 4 contracts
Samples: Operating Agreement (Cinergy Corp), Limited Liability Company Agreement (Cinergy Corp), Operating Agreement (Cinergy Corp)
Tax Credits and Similar Items. Any tax credits or similar items not allocable pursuant to Sections 4.2.1 through 4.2.5 shall be allocated to the Interest Holders in proportion to their respective Income Percentages. Notwithstanding the preceding sentence, if Company expenditures that give rise to tax credits also give rise to Member Nonrecourse Deductions, the tax credits attributable to such expenditures shall be allocated in accordance with Treasury Regulation Section 1.704-1(b)(4)(ii1 (b)(4)(ii).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Tesoro Sierra Properties LLC)
Tax Credits and Similar Items. Any tax credits or similar items not allocable pursuant to Sections 4.2.1 Section 4.1(a) through 4.2.5 4.1(e) shall be allocated to the Interest Holders Members in proportion to their respective Allocation Percentages. Notwithstanding the preceding sentence, if Company expenditures that give rise to tax credits also give rise to Member Nonrecourse Deductions, the tax credits attributable to such expenditures shall be allocated in accordance with Treasury Regulation Section 1.704-1(b)(4)(iil(b)(4)(ii).
Appears in 1 contract
Samples: Operating Agreement (Liveworld Inc)
Tax Credits and Similar Items. Any tax credits or similar items not allocable pursuant to Sections 4.2.1 through 4.2.5 shall be allocated to the Interest Holders in proportion to their respective Income Percentages. Notwithstanding the preceding sentence, if Company expenditures that give rise to tax credits also give rise to Member Nonrecourse Deductions, the tax credits attributable to such expenditures shall be allocated in accordance with Treasury Regulation Section 1.704-1(b)(4)(ii).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Tesoro Sierra Properties LLC)
Tax Credits and Similar Items. Any tax credits or similar items not allocable pursuant to Sections 4.2.1 through 4.2.5 shall be allocated to the Interest Holders in proportion to their respective Income Percentages. Notwithstanding the preceding sentence, if Company expenditures that give rise to tax credits also give rise to Member Nonrecourse Deductions, the tax credits attributable to such expenditures shall be allocated in accordance with Treasury Regulation Section 1.704-1(b)(4)(iil(b)(4)(ii).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Tesoro Sierra Properties LLC)