Common use of Tax Treatment of Additional or Substituted Members Clause in Contracts

Tax Treatment of Additional or Substituted Members. No Additional or Substituted Class A Members (described below) shall be entitled to any retroactive allocation of Losses, income, or expense deductions incurred by the Company. The Manager may, at its option, at the time an Additional or Substituted Member is admitted, close the Company books (as though the Company’s tax year had ended) or make pro rata allocations of loss, income, and expense deductions to the Additional or Substituted Member for that portion of the Company’s tax year in which the Additional Member was admitted in accordance with the provisions of section 706(d) of the IRS Code and the Treasury Regulations promulgated thereunder.

Tax Treatment of Additional or Substituted Members. No Additional or Substituted Class A Members (described below) shall be entitled to any retroactive allocation of Losses, income, or expense deductions incurred by the Company. The Manager may, at its option, at the time an Additional or Substituted Member is admitted, close the Company books (as though the Company’s tax year had ended) or make pro rata allocations of loss, income, and expense deductions to the Additional or Substituted Member for that portion of the Company’s tax year in which the Additional Member was admitted in accordance with the provisions of section 706(d) of the IRS Code and the Treasury Regulations promulgated thereunder.

Tax Treatment of Additional or Substituted Members. No Additional or Substituted Class A Members (described below) shall be entitled to any retroactive allocation of Losses, income, or expense deductions deduction incurred by the Company. The Manager may, at its option, at the time an Additional or Substituted Member is admitted, close the Company books (as though the Company’s Company tax year had ended) or make pro rata allocations of loss, income, and expense deductions to the Additional or Substituted Member for that portion of the Company’s Company tax year in which the Additional Member was admitted in accordance with the provisions of section 706(d) of the IRS Code and the Treasury Regulations promulgated thereunder.