Allocations of Income and Loss. For each taxable year, each holder of Preferred Units will be allocated a portion of the Net Income and Net Loss of the Partnership equal to the portion of the Net Income and Net Loss of the Partnership that would be allocated to such holder pursuant to Article 6 of the Agreement if such holder held a number of Partnership Common Units equal to (i) the number of Preferred Units held by such holder, multiplied by (ii) 0.5. Upon liquidation, dissolution or winding up of the Partnership, the Partnership shall endeavor to allocate income and gain to the holders of the Preferred Units such that the Capital Accounts related to the Preferred Units are equal to their Liquidation Preference.
Allocations of Income and Loss. For each taxable year, (i) each holder of Preferred Units will be allocated net income of the Partnership in an amount equal to the distributions made on such holder's Preferred Units during such taxable year, and (ii) each holder of Preferred Units will be allocated its pro rata share, based on the portion of outstanding Preferred Units held by it, of any net loss of the Partnership that is not allocated to holders of Partnership Common Units or other interests in the Partnership. Upon liquidation, dissolution or winding up of the Partnership, the holders of Preferred Units will be allocated income and gain sufficient to enable them to realize the Liquidation Preference in full.
Allocations of Income and Loss. Subject to the terms of Section 5 hereof, for each taxable year, (i) each holder of Preferred Units will be allocated, to the extent possible, net income of the Partnership in an amount equal to the distributions made on such holder’s Preferred Units during such taxable year, and (ii) each holder of Preferred Units will be allocated its pro rata share, based on the portion of outstanding Preferred Units held by it, of any net loss of the Partnership that is not allocated to holders of Partnership Common Units or other interests in the Partnership.
Allocations of Income and Loss. (a) BOOK ALLOCATIONS. The net income and net loss of the Company shall be allocated entirely to the Capital Account of the Sole Member.
Allocations of Income and Loss. All items of income or loss of the Partnership shall be allocated to the Partners in accordance with the provisions of Exhibit C attached hereto, which are hereby incorporated by reference for all purposes of this Agreement.
Allocations of Income and Loss. (a) Taxable gains shall be first allocated to those Members and Economic Interest Owners, if any, with negative capital accounts, pro rata according to their negative capital accounts, until all such accounts have been returned to zero.
(b) After the allocations are made pursuant to Section 6.2(a), all allocations and distributions of Income and Loss from whatever source shall then be made according to the Economic Interest of each Member and Economic Interest Owner.
(c) In accordance with Code Section 704(c) and the Regulations thereunder, Income and Loss with respect to that portion of the property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Members so as to take account of any variation between the adjusted basis of such property to the Company for Federal income tax purposes and its initial fair market value used as the book value of the property by the Company.
Allocations of Income and Loss. The Company's net taxable income and loss shall be allocated among the Members as set forth in Schedule 4 hereto.
Allocations of Income and Loss. (a) Income shall be first allocated to those Partners and Assignees, if any, with negative Adjusted Capital Account balances, pro rata according to their negative Adjusted Capital Account balances, until all such balances have been returned to zero.
(b) After the allocations are made pursuant to Section 6.2(a), all allocations of Income and Loss from whatever source shall then be made according to the Economic Interest of each Partner and Assignee.
(c) In accordance with Code Section 704(c) and the Regulations thereunder, Income and Loss with respect to that portion of the property contributed to the capital of the Partnership shall, solely for tax purposes, be allocated among the Partners so as to take account of any variation between the adjusted basis of such property to the Partnership for Federal income tax purposes and its initial fair market value used as the book value of the property by the Partnership.
(d) Notwithstanding anything in this Agreement to the contrary, no Partner or Assignee shall be entitled to any allocation of Loss if such allocation would result in such Partner or Assignee having a negative Adjusted Capital Account while any other Partner or Assignee has a positive Adjusted Capital Account. In such event, the Losses shall be allocated to the Partners or Economic Interest Owners with positive Adjusted Capital Accounts until their Adjusted Capital Accounts have been reduced to zero or until the negative amount in the Adjusted Capital Accounts are proportionately the same as the negative accounts of the other Partners or Assignee as measured by their respective Economic Interests in the Partnership. Additionally, HM shall at all times during the existence of the Partnership have at least a 1% interest in each material item of Partnership income, gain, loss, deduction or credit.
Allocations of Income and Loss. Income and losses of the Partnership shall be allocated and charged to the Capital Accounts of the Partners in accordance with the provisions of the Appendix attached hereto, all the terms of which are incorporated herein by reference.
Allocations of Income and Loss. Subject to the provision of Section 4.3, the Company's items of Net Income and Loss from Operations for each Fiscal Year and gain and loss realized by the Company in connection with each Capital Transaction, after giving effect to all Capital Account adjustments attributable to contributions and distributions of money and property made during such Fiscal Year (but excluding income and loss, if any, that is required to be separately determined and allocated to the Members for federal income tax purposes in the same manner as prescribed under section 704(c) of the Code), shall be allocated to the Members, pro rata in accordance to their respective Ownership Percentages.
