Transfer of or Change in Interests. The Tax Matters Partner, subject to the supervision of the Board of Directors, is authorized to use any convention or combination of conventions likely to be upheld for federal income tax purposes regarding the allocation of items of Company income, gain, loss, deduction and expense with respect to a new Member's Interest, a transferred Interest and a withdrawn Interest. A transferee who takes all or part of a Member's Interest shall succeed to the Capital Account of the transferor Member to the extent it relates to the whole or partial Interest transferred.
Transfer of or Change in Interests. The Managers are authorized to adopt any convention or combination of conventions likely to be upheld for federal income tax purposes regarding the allocation and/or special allocation of items of Company income, gain, loss, deduction and expense with respect to a newly issued Interest, a transferred Interest and a redeemed Interest. Upon admission as a Substituted Member, a transferee of an Interest shall succeed to the Capital Account of the transferor Member to the extent it relates to the transferred Interest.
Transfer of or Change in Interests. The General Partner is authorized to adopt any convention or combination of conventions likely to be upheld for federal income tax purposes regarding the allocation and/or special allocation of items of Partnership income, gain, loss, deduction and expense with respect to a newly issued Interest, a transferred Interest and a redeemed Interest. A transferee of an Interest in the Partnership shall succeed to the Capital Account of the transferor Partner to the extent it relates to the transferred Interest.
Transfer of or Change in Interests. The Directors are authorized to adopt any convention or combination of conventions likely to be upheld for federal income tax purposes regarding the allocation and/or special allocation of items of Fund income, gain, loss, deduction and expense with respect to newly issued Interests, transferred Interests and withdrawn Interests. Upon admission as a Substituted Limited Partner, a transferee of Interests shall succeed to the Capital Account of the transferor Limited Partner to the extent it relates to the transferred Interests.
Transfer of or Change in Interests. The Trustees are authorized to adopt any convention or combination of conventions that they believe are reasonable for federal income tax purposes regarding the allocation and/or special allocation of items of Trust income, gain, loss, deduction and expense with respect to a newly issued Unit, a transferred Unit or a redeemed Unit. A transferee of a Unit of the Trust shall succeed to the Capital Account of the transferor Unitholder to the extent it relates to the transferred Units of the Trust. Neither the Trust nor the Trustees shall be required to provide any information to a transferee Unitholder in connection with an election by such transferee Unitholder under Code Section 732(d).
Transfer of or Change in Interests. The Managing Member is authorized to adopt any convention or combination of conventions likely to be upheld for federal income tax purposes regarding the allocation and/or special allocation of items of Company income, gain, loss, deduction and expense with respect to a newly issued Interest, a transferred Interest and a redeemed Interest. A transferee of an Interest shall succeed to the Capital Account of the transferor Member to the extent it relates to the transferred Interest.
Transfer of or Change in Interests. The Board of Directors is authorized to adopt any convention or combination of conventions that will be upheld for federal income tax purposes regarding the allocation and/or special allocation of items of Partnership income, gain, loss, deduction and expense with respect to a newly issued Interest, a transferred Interest and a redeemed Interest. Upon admission as a Substituted Partner, a transferee of an Interest shall succeed to the Capital Account of the transferor Partner to the extent it relates to the transferred Interest.
Transfer of or Change in Interests. The Trustees may use any convention or combination of conventions that they believe is reasonable for U.S. federal income tax purposes regarding the allocation of items of income, gain, loss, deduction and expense with respect to transferred and/or redeemed Units. A transferee who takes all or part of a Unitholder's Units shall succeed to the Capital Account maintained in respect of the transferor Unitholder to the extent of such transfer.
Transfer of or Change in Interests. The Credit Committee is authorized to adopt any convention or combination of conventions likely to be upheld for federal income tax purposes regarding the allocation and/or special allocation of items of Company income, gain, loss, deduction and expense with respect to a newly issued Interest, a transferred Interest and a redeemed Interest. A transferee of an Interest in the Company shall succeed to the Capital Account of the transferor Member to the extent it relates to the transferred Interest.
Transfer of or Change in Interests. Except as provided in Section 706(d) (2) of the Code, if during any taxable year of the Partnership, there is a Transfer of or a change in any Partner’s Interest in the Partnership, each Partner’s allocable share of any item of income, gain, loss, deduction, or credit of the Partnership for such taxable year shall be determined by the use of any method (as determined by the Management Committee) permitted by the Treasury Regulations which takes into account the varying interests of the Partners in the Partnership during such taxable year.
