Tax Return and Tax Basis Capital Account Allocations. 6.2.1 Unless otherwise expressly provided in this Sec. 6.2, the allocations of the Partnership's items of income, gain, loss, or deduction for tax return and tax basis capital account purposes shall follow the principles of the allocations under Sec. 6.1. However, the Partnership's gain or loss on the taxable disposition of a Partnership property in excess of the gain or loss under Sec. 6.1, if any, is allocated to the contributing Party to the extent of such Party's pre-contribution gain or loss. JOA - Exhibit "F"
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Samples: Exploration Participation Agreement (Ridgewood Energy U Fund LLC), Exploration Participation Agreement (Ridgewood Energy P Fund LLC)
Tax Return and Tax Basis Capital Account Allocations. 6.2.1 Unless otherwise expressly provided in this Sec. 6.2, the allocations of the Partnership's ’s items of income, gain, loss, or deduction for tax return and tax basis capital account purposes shall follow the principles of the allocations under Sec. 6.1. However, the Partnership's ’s gain or loss on the taxable disposition of a Partnership property in excess of the gain or loss under Sec. 6.1, if any, is allocated to the contributing Party to the extent of such Party's ’s pre-contribution gain or loss. JOA - Exhibit "F".
Appears in 2 contracts
Samples: Exploration and Development Agreement (ZaZa Energy Corp), Asset Purchase Agreement (Ausam Energy Corp)
Tax Return and Tax Basis Capital Account Allocations. 6.2.1 Unless otherwise expressly provided in this Sec. 6.2, the allocations of the Partnership's ’s items of income, gain, loss, or deduction for tax return and tax basis capital account purposes shall follow the principles of the allocations under Sec. 6.1. However, the Partnership's ’s gain or loss on the taxable disposition of a Partnership property properly in excess of the gain or loss under Sec. 6.1, if any, is allocated to the contributing Party to the extent of such Party's ’s pre-contribution gain or loss. JOA - Exhibit "F".
Appears in 1 contract
Samples: Exploration and Development Agreement (ZaZa Energy Corp)
Tax Return and Tax Basis Capital Account Allocations. 6.2.1 Unless otherwise expressly provided in this Sec. Section 6.2, the allocations of the Partnership's partnership items of income, gain, loss, or deduction for tax return and tax basis capital account purposes shall follow the principles of the allocations under Sec. Section 6.1. However, the Partnershippartnership's gain or loss on the taxable disposition of a Partnership partnership property in excess of the gain or loss under Sec. Section 6.1, if any, is allocated to the contributing Party to the extent of such Party's pre-contribution gain or loss. JOA - Exhibit "F".
Appears in 1 contract
Samples: Offshore Operating Agreement (Ridgewood Energy P Fund LLC)