Tax Purposes. Allocations under this Section 6.4 are solely for purposes of federal, state and local income taxes and will not affect, or in any way be taken into account in computing, any Partner’s Capital Account or share of Profits, Losses or other items or distributions under any provision of this Agreement.
Tax Purposes. In the event the Gross Asset Value of any Company asset is adjusted pursuant to subparagraph 1.
Tax Purposes. The provisions of this Indenture shall be interpreted to further this intention and agreement of the parties.
Tax Purposes. Bio Marin represents, warrants and covenants:
Tax Purposes. The parties hereto shall cooperate fully with respect to the reporting and defense of the position set forth in this Section 7.21.
Tax Purposes. This Section is intended to identify some of my express purposes in creating this Trust. All provisions of this Trust or the trust created under this Trust (collectively referred to as the Trust) shall be construed so as best to effect these express purposes. No Trustee shall exercise any discretion in a manner that may reasonably be expected to frustrate the accomplishment of any of these express purposes.
Tax Purposes. The Parties agree (1) to be bound by the allocation of assets on Exhibit 2.1 for all federal, state, and local income tax purposes and (2) to file Internal Revenue Service Form 8594 (and other forms required by law) in accordance with the allocation of assets on Exhibit 2.1.
Tax Purposes. If any Partnership assets are reflected in the capital accounts of the Partners and on the books of the Partnership at a book value that differs from the tax basis of such assets, then items attributable to such property for U.S. federal income tax purposes shall be shared among the Partners in a manner that take account of the variation between such tax basis and book value in the same way as variations between the tax basis and fair market value of property contributed to the Partnership would be taken into account under Code Section 704(c).
Tax Purposes. Each Holder by acceptance of its Note agrees to treat its Note as debt for United States federal income tax purposes.
Tax Purposes. Section 4.7. Non-Liquidation Event Distributions on Partnership Interests...........................8 (a) Distributions of Cash...............................................................8 (b) Limitation..........................................................................8 (c)
