ALLOCATIONS OF NET GAIN OR LOSS Clause Samples

ALLOCATIONS OF NET GAIN OR LOSS. The Net Gain and Net Loss of the Partnership for a fiscal year shall be allocated among the persons who were Partners during such fiscal year in a manner that will, as nearly as possible, reflect the distributions actually made by the Partnership to such Partners. Without derogating from the generality of the foregoing, such allocations shall, as nearly as possible, cause the Capital Account balance of each Partner at the end of such fiscal year to be equal to the excess (which may be negative) of: 8.2.1.1 the hypothetical distribution (if any) that such Partner would receive if, on the last day of such fiscal year, (x) all Partnership assets, including cash, were sold for cash equal to their Value, taking into account any adjustments thereto for such fiscal year, (y) all Partnership liabilities were satisfied in cash according to their terms (limited, with respect to each nonrecourse liability, to the Value of the assets securing such liability) and (z) the net proceeds thereof (after satisfaction of such liabilities) were distributed in full pursuant to 7.2. hereof, over 8.2.1.2 the amount, if any, which such Partner is obligated to contribute to the capital of the Partnership as of the last day of such fiscal year.
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ALLOCATIONS OF NET GAIN OR LOSS. (a) Net Gain or Net Loss (or items thereof) for any taxable period shall be allocated among the Members in a manner that is consistent with the distribution and other economic provisions of this Agreement and the requirements of Section 704 of the Code, in each case as determined by the Management Committee. (b) For federal, state and local income tax purposes, items of Company income, gain, loss deduction and credit for each taxable year of the Company shall be allocated among the Members in a manner that is generally consistent with the allocations of Net Gain and Net Loss (and items thereof) set forth in 8.2(a) and the requirements of Section 704(c) of the Code, the Treasury Regulations thereunder and any similar provisions of state or local income tax law, in each case as determined by the Management Committee.
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Related to ALLOCATIONS OF NET GAIN OR LOSS

  • Allocations of Net Income and Net Loss Except as otherwise provided in this Agreement, after giving effect to the special allocations in subparagraph 1(c) and paragraph 2, Net Income, Net Loss and, to the extent necessary, individual items of income, gain, loss or deduction, of the Partnership for each fiscal year or other applicable period of the Partnership shall be allocated among the General Partner and Limited Partners in accordance with their respective Percentage Interests.

  • Allocations of Net Profits and Net Losses Except as otherwise set forth herein, Net Profits and Net Losses shall be allocated for each Fiscal Year to the Members in proportion to their respective Capital Accounts.

  • Allocations of Profits and Losses Except as otherwise provided in this Agreement, Profits and Losses (and, to the extent necessary, individual items of income, gain or loss or deduction of the Partnership) shall be allocated in a manner such that the Capital Account of each Partner after giving effect to the Special Allocations set forth in Section 5.05 is, as nearly as possible, equal (proportionately) to (i) the distributions that would be made pursuant to Article IV if the Partnership were dissolved, its affairs wound up and its assets sold for cash equal to their Carrying Value, all Partnership liabilities were satisfied (limited with respect to each non-recourse liability to the Carrying Value of the assets securing such liability) and the net assets of the Partnership were distributed to the Partners pursuant to this Agreement, minus (ii) such Partner’s share of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain, computed immediately prior to the hypothetical sale of assets. For purposes of this Article V, each Unvested Unit shall be treated as a Vested Unit. Notwithstanding the foregoing, the General Partner shall make such adjustments to Capital Accounts as it determines in its sole discretion to be appropriate to ensure allocations are made in accordance with a partner’s interest in the Partnership.

  • Allocation of Net Profits and Net Losses As of the last day of each Fiscal Period, any Net Profits or Net Losses for the Fiscal Period shall be allocated among and credited to or debited against the Capital Accounts of the Members in accordance with their respective Investment Percentages for such Fiscal Period.

  • Allocation of Net Income and Net Loss Net Income or Net Loss of the Partnership shall be determined as of the end of each calendar year and as of the end of any interim period extending through the day immediately preceding any (i) disproportionate Capital Contribution, (ii) disproportionate distribution, (iii) Transfer of a Partnership Interest in accordance with the terms of this Agreement, or (iv) Withdrawal Event. If a calendar year includes an interim period, the determination of Net Income or Net Loss for the period extending through the last day of the calendar year shall include only that period of less than twelve (12) months occurring from the day immediately following the last day of the latest interim period during the calendar year and extending through the last day of the calendar year. For all purposes, including income tax purposes, Net Income, if any, of the Partnership for each calendar year or interim period shall be allocated among the Partners in proportion to their respective Partnership Percentages for the calendar year or interim period. In the event of a Net Loss for a particular calendar year or interim period, then, for such calendar year or interim period, the Net Loss for such calendar year or interim period shall be allocated among the Partners in proportion to their respective Partnership Percentages for the calendar year or interim period.