Forfeiture Allocations definition

Forfeiture Allocations has the meaning set forth in Section 6.2(e).

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Forfeiture Allocations has the meaning set forth in Section 4.2.

Forfeiture Allocations mean allocations, to a Restricted Unit Member who has made a Section 83(b) election with respect to the Member's Interest, of gross income and gain or gross deduction and loss (to the extent such items are available) for the taxable year of the forfeiture of such Interest in a positive or negative amount equal to (1) the excess (not less than zero) of (a) the amount of distributions to the Member with respect to such Member's Membership Interest over (b) the amounts paid for such Membership Interest minus (2) the cumulative net income (or loss) allocated to the Restricted Unit Member with respect to such Member's Membership Interest.

Examples of Forfeiture Allocations in a sentence

For the avoidance of doubt, the Company is entitled to make Forfeiture Allocations and, once required by applicable final or temporary guidance, allocations of Net Income and Net Loss shall be made in accordance with Proposed Treasury Regulation Section 1.704-1(b)(4)(xii)(c) or any successor provision or guidance.
For the avoidance of doubt, the Company is entitled to make Forfeiture Allocations and, once required by applicable final or temporary guidance, allocations of Net Income and Net Loss will be made in accordance with Proposed Treasury Regulation Section 1.704-1(b)(4)(xii)(c) or any successor provision or guidance.
For the avoidance of doubt, the Company is entitled to make Forfeiture Allocations and, once required by applicable final or temporary guidance, allocations of Net Income and Net Loss will be made in accordance with Proposed Treasury Regulations Section 1.704-1(b)(4)(xii)(c) or any successor provision or guidance.
For the avoidance of doubt, the Board is entitled to make Forfeiture Allocations and, once required by applicable final or temporary guidance, allocations of Profits and Losses will be made in accordance with Proposed Treasury Regulation Section 1.704-1(b)(4)(xii)(c) or any successor provision or guidance or any applicable Internal Revenue Service guidance with respect to safe harbor elections.
For the avoidance of doubt, the Board is entitled to make Forfeiture Allocations and, once required by applicable final or temporary guidance, allocations of Profits and Losses will be made in accordance with Proposed Treasury Regulation Section 1.704-1(b)(4)(xii)(c) or any successor provision or guidance or any applicable Internal Revenue Service guidance with respect to Safe Harbor Elections.
The Company shall make Forfeiture Allocations with respect to any unvested Class B Units that have been forfeited.
For purposes of allocating all Profits and Losses, pursuant to this Section 4.2 (and Sections 4.3 and 4.4, to the extent applicable), all outstanding Class A Common Units shall be treated as vested; provided, that in the event that a Unitholder’s unvested Class A Common Units are forfeited or repurchased, Forfeiture Allocations as described in Section 4.3(h) will be made.
For the avoidance of doubt, the LLC is entitled to make Forfeiture Allocations and, once required by applicable final or temporary guidance, allocations of Profits and Losses will be made in accordance with Proposed Treasury Regulation Section 1.704-1(b)(4)(xii)(c) or any successor provision or guidance.
For purposes of allocating all Profits and Losses, pursuant to this Section 4.2 (and any allocations made pursuant to Sections 4.3 and 4.4, to the extent applicable), all outstanding Class A Common Units shall be treated as vested; provided, that in the event that a Unitholder’s unvested Class A Common Units are forfeited or repurchased, Forfeiture Allocations as described in Section 4.3(g) will be made.
For the avoidance of doubt, the Company is entitled to make Forfeiture Allocations and, once required by applicable final or temporary guidance, allocation of Profits and Losses will be made in accordance with Proposed Treasury Regulation Section 1.704-1(b)(4)(xii)(c) or any successor provision or guidance.

More Definitions of Forfeiture Allocations

Forfeiture Allocations has the meaning set forth in Section 6.4(f). “Fresh Benefit” has the meaning set forth in Section 9.4.

Forfeiture Allocations has the meaning set forth in Section VI.2(e).