Tax Incidents. It is intended that the Company will be treated as a pass-through entity for tax purposes. Subject to Section 704(c) of the Code, for U.S. federal and state income tax purposes, all items of Company income, gain, loss, deduction, credit and any other allocations not otherwise provided for shall be allocated among the Members in the same manner as the corresponding item of income, gain, loss or deduction was allocated pursuant to the preceding Sections of this Article V.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Hanover Capital Mortgage Holdings Inc), Operating Agreement (Matrix Bancorp Inc), Limited Liability Company Agreement (Hanover Capital Mortgage Holdings Inc)
Tax Incidents. It is intended that the Company will be treated as a pass-through entity for tax purposes. Subject to Section 704(c) of the Code, for U.S. federal and state income tax purposes, all items of Company income, gain, loss, deduction, credit and any other allocations not otherwise provided for shall be allocated among the Members in the same manner as the corresponding item of income, gain, loss or deduction was allocated pursuant to the preceding Sections of this Article V.ARTICLE IV.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Hydron Technologies Inc), Limited Liability Company Agreement (Public Media Works Inc)
Tax Incidents. It is intended that the Company will be treated as a pass-through entity for tax purposes. Subject to Section 704(c) of the Code, for U.S. federal federal, state and state local income tax purposes, all items of Company income, gain, loss, deduction, credit and any other allocations not otherwise provided for shall be allocated among the Members in the same manner as the corresponding item of income, gain, loss or deduction was allocated pursuant to the preceding Sections sections of this Article V.
Appears in 1 contract
Samples: Limited Liability Company Agreement (NextDecade Corp.)
Tax Incidents. It is intended that the Company will be treated as a pass-through entity for tax purposes. Subject to Section 704(c) of the Code, for U.S. federal and state income tax purposes, all items of Company income, gain, loss, deduction, credit and any other allocations not otherwise provided for shall be allocated among the Members in the same manner as the corresponding item of income, gain, loss or deduction was allocated allocated, separately or as part of Net Profits or Net Losses, pursuant to the preceding Sections of this Article ARTICLE V.
Appears in 1 contract
Tax Incidents. It is intended that the Company will be treated as a pass-through entity for U.S. tax purposes. Subject to Section 704(c) of the Code, for U.S. federal and state income tax purposes, purposes all items of Company incomegross sales, cost of goods sold, Income, gain, lossLoss, deduction, credit and any other allocations not otherwise provided for shall be allocated among the Members in the same manner as the corresponding item of income, gain, loss or deduction was allocated pursuant to the preceding Sections sections of this Article V..
Appears in 1 contract
Samples: Operating and Member Control Agreement (Juhl Energy, Inc)
Tax Incidents. It is intended that the Company will be treated as a pass-through entity for U.S. tax purposes. Subject to Section 704(c) of the Code, for U.S. federal and state income tax purposes, purposes all items of Company incomegross sales, cost of goods sold, Income, gain, lossLoss, deduction, credit and any other allocations not otherwise provided for shall be allocated among the Members in the same manner as the corresponding item of income, gain, loss or deduction was allocated pursuant to the preceding Sections sections of this Article V.Section 7.
Appears in 1 contract
Samples: Operating and Member Control Agreement (Juhl Energy, Inc)