Transferor-Transferee Allocations. Income, gain, loss, deduction or credit attributable to any Units which have been Transferred shall be allocated between the transferor and the transferee under any method allowed under Code Section 706 and the Regulations thereunder as agreed by the transferor and the transferee.
Transferor-Transferee Allocations. If a Share is transferred in compliance with the provisions of this Article 13, the income, gains, losses, deductions, and credits allocable in respect of that Share shall be allocated to the days of the Taxable Period to which they are economically attributable, and then prorated between the transferor and the transferee on the basis of the number of days in the Taxable Period that each was the holder of that interest.
Transferor-Transferee Allocations. If a Unit is transferred in compliance with the provisions of this Article 9, the income, gains, losses, deductions, and credits allocable in respect of that Unit shall be allocated between the transferor and transferee in accordance with Section 5.7.
Transferor-Transferee Allocations. If a Unit is transferred in compliance with the provisions of this Article 13, the income, gains, losses, deductions, and credits allocable in respect of that Unit shall be allocated to the days of the taxable year to which they are economically attributable, and then prorated between the transferor and the transferee on the basis of the number of days in the Taxable Period that each was the holder of that interest.
Transferor-Transferee Allocations. As between a Limited Partner and his transferee, profits and losses for any month shall be apportioned to the person who is the holder of that Limited Partnership Interest transferred on the last day of such month, without regard to the results of the Partnership's operations during the period before and after such transfer. A transferee of, or substitute Limited Partner for, a Limited Partner's Limited Partnership Interest shall be entitled to receive distributions from the Partnership with respect to such Limited Partnership Interest only after the effective date of such assignment.
Transferor-Transferee Allocations. Unless otherwise agreed in writing by a transferor and transferee of a Partnership Interest herein, Distributable Cash distributable with respect to any Partnership Interest which may have been transferred during any year shall be distributed to the holder of such Partnership Interest who was recognized as the owner on the date of such distribution, without regard to the results of Partnership operations during the year.
Transferor-Transferee Allocations. If a Partnership Interest is transferred during any year, the income, gains losses, and deductions allocable in respect of that Partnership Interest shall be prorated between the transferor and the transferee on the basis of the number of days in the year that each was the holder of that interest without regard to the results of the Partnership operations (or cash distributions made) during the period before and after the transfer unless the transferor and transferee agree to an allocation based on the results as of the record date of transfer and agree to reimburse the Partnership for the cost of making and reporting their agreed allocation. Notwithstanding the foregoing, no allocation shall be made which is not allowed by Section 706(d) of the Code.
Transferor-Transferee Allocations. As between a Partner and his transferee, profits and losses for any month shall be apportioned to the person who is the holder of the Limited Partnership Interest transferred on the last day of such month, without regard to the results of the Partnership's operations during the period before and after such transfer.
Transferor-Transferee Allocations. Income, gain, loss and deduction attributable to any Partnership Interest which has been transferred shall be allocated between the transferor and the transferee in any method as agreed by the transferor and the transferee.
Transferor-Transferee Allocations. Unless otherwise agreed in writing by a transferor and transferee of a Membership Interest herein, Distributable Cash distributable with respect to any Membership Interest which may have been transferred during any year shall be distributed to the holder of such Membership Interest who was recognized as the owner on the date of such distribution, without regard to the results of Company operations during the year.
