Additional Allocations. Notwithstanding the foregoing, if, upon the final dissolution and termination of the Partnership and after taking into account all allocations of Net Income and Net Losses (and other tax items) under this Article IV, the distributions to be made in accordance with the positive Capital Account balances would result in a distribution that would be different from a distribution under Article XIII, then gross items of income and gain (and other tax items) for the taxable year of the final dissolution and termination (and, to the extent permitted under section 761(c) of the Code, gross items of income and gain, and other tax items, for the immediately preceding taxable year) shall be allocated to the Partners to increase or decrease their respective Capital Account balances so that the final distribution will occur in the same manner as a distribution under Section 13.4.
Additional Allocations. Notwithstanding the foregoing provisions of this Section 4.7,
Additional Allocations. If a terminated Participant receives a complete distribution of his/her vested Account Balance while still entitled to an additional allocation, the Cash-Out Distribution forfeiture provisions do not apply until the Participant receives a distribution of the additional amounts to be allocated. (See Section 7.10(a)(1) of the Plan.) To modify the default Cash-Out Distribution forfeiture rules, complete this AA §8-9(a). □ The Cash-Out Distribution forfeiture provisions will apply if a terminated Participant takes a complete distribution, regardless of any additional allocations during the Plan Year.
Additional Allocations. Notwithstanding any other provisions of this Section 5.4, the following special allocations shall be made for each taxable period:
Additional Allocations. The following special allocations shall be made:
Additional Allocations. Notwithstanding anything to the contrary in this Agreement, all allocations under this Agreement shall be adjusted insofar as may be required to enable the Partnership to meet the requirements of Section 514(c)(9)(E) of the Code and the Regulations thereunder so that all allocations hereunder have "substantial economic effect" within the meaning of Section 704(b)(2) of the Code and so that, as to each Partner which is a Qualified Organization and the General Partner,
Additional Allocations. Additional provisions respecting allocations are set forth in Appendix B hereto and are incorporated by reference herein.
Additional Allocations. (a) Allocation of Member Nonrecourse Deductions When Member Bears Economic Risk of Loss. Notwithstanding the provisions of Section 5.1 and subject to the provisions of Section 5.2(c), items of loss and deduction and Section 705(a)(2)(B) Expenditures attributable, under Treasury Regulation Section 1.704-2(i), to Member Nonrecourse Debt shall be allocated to the Members in accordance with the ratios in which they bear the economic risk of loss for such debt (as determined pursuant to Treasury Regulation Section 1.752-3).
Additional Allocations. Unless specified otherwise in the Adoption Agreement, in the event that the allocations made pursuant to subsections (a), (b), (c), (e) or (f) of this Section 4.06, would result in a failure to satisfy the requirements of Code section 410(b), or of the regulations thereunder, the Plan Administrator may determine that an additional number of Nonhighly Compensated Employees shall be eligible to share in the allocation made under such subsections. Such additional number of such Nonhighly Compensated Employees shall be the minimum number necessary to enable the Plan to qualify under Code section 410(b). Such additional Nonhighly Compensated Employees who shall be eligible to share in such allocation shall be selected in the following order:
Additional Allocations. Notwithstanding the foregoing, if, upon the final dissolution and termination of the Company and after taking into account all allocations of Income and Losses (and other tax items) under this Section 5.1, the distributions to be made in accordance with the positive Capital Account balances would result in a distribution that would be different from the Distribution Hierarchy provided for under Section 5.2(a) below, then gross items of Income (and other tax items) for the taxable year of the final dissolution and termination (and, to the extent permitted under section 761(c) of the Code, gross items of Income (and other tax items) for the immediately preceding taxable year) shall be allocated to the Members to increase or decrease Capital Account balances, as the case may be, so that the final distribution will occur in under the Distribution Hierarchy provided for under Section 5.2(a) below.
