Allocations for Tax Purposes in General. (a) Except as otherwise provided in this Section 5.3, each item of income, gain, loss and deduction of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections 5.1 and 5.2.
Appears in 30 contracts
Samples: Limited Liability Company Agreement (Inspirato Inc), Limited Liability Company Agreement (Inspirato Inc), Limited Liability Company Agreement
Allocations for Tax Purposes in General. (a) Except as otherwise provided in this Section 5.3, each item of income, gain, loss loss, deduction, and deduction credit of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections 5.1 and 5.2.
Appears in 14 contracts
Samples: Limited Liability Company Agreement (Kimbell Tiger Acquisition Corp), Limited Liability Company Agreement (Kimbell Tiger Acquisition Corp), Limited Liability Company Agreement (Kimbell Tiger Acquisition Corp)
Allocations for Tax Purposes in General. (a) Except as otherwise provided in this Section 5.34.3, each item of income, gain, loss loss, deduction and deduction credit of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections 5.1 Section 4.1 and 5.2Section 4.2.
Appears in 11 contracts
Samples: Limited Liability Company Agreement (Hagerty, Inc.), Limited Liability Company Agreement (Hagerty, Inc.), Limited Liability Company Agreement (Stronghold Digital Mining, Inc.)
Allocations for Tax Purposes in General. (a) Except as otherwise provided in this Section 5.34.3, each item of income, gain, loss and deduction of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections 5.1 4.1 and 5.24.2.
Appears in 9 contracts
Samples: Limited Liability Company Operating Agreement (Cactus, Inc.), Limited Liability Company Operating Agreement (Cactus, Inc.), Limited Liability Company Operating Agreement
Allocations for Tax Purposes in General. (a) Except as otherwise provided in this Section 5.35.3 or Section 5.4, each item of income, gain, loss and deduction of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections 5.1 and 5.2.
Appears in 6 contracts
Samples: Limited Liability Company Agreement (Brigham Minerals, Inc.), Limited Liability Company Agreement (Brigham Minerals, Inc.), Limited Liability Company Agreement (Brigham Minerals, Inc.)
Allocations for Tax Purposes in General. (a) Except as otherwise provided in this Section 5.34.3, each item of income, gain, loss and deduction of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections 5.1 4.1 and 5.24.2.
Appears in 6 contracts
Samples: Limited Liability Company Agreement (Spark Energy, Inc.), Limited Liability Company Agreement (Spark Energy, Inc.), Limited Liability Company Agreement (Spark Energy, Inc.)
Allocations for Tax Purposes in General. (a) Except as otherwise provided in this Section 5.34.4, each item of income, gain, loss and deduction of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections 5.1 Section 4.2 and 5.2Section 4.3.
Appears in 5 contracts
Samples: Limited Liability Company Agreement (Stagwell Inc), Limited Liability Company Agreement (Stagwell Inc), Limited Liability Company Agreement (Stryve Foods, Inc.)
Allocations for Tax Purposes in General. (a) Except as otherwise provided in this Section 5.3, each item of income, gain, loss and deduction of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections 5.1 and 5.2.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Parsley Energy, Inc.), Limited Liability Company Agreement (Parsley Energy, Inc.), Limited Liability Company Agreement (Parsley Energy, Inc.)
Allocations for Tax Purposes in General. (a) a. Except as otherwise provided in this Section 5.3, each item of income, gain, loss and deduction of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections 5.1 and 5.2.
Appears in 3 contracts
Samples: Registration Rights Agreement (Earthstone Energy Inc), Limited Liability Company Agreement (Earthstone Energy Inc), Contribution Agreement (Earthstone Energy Inc)
Allocations for Tax Purposes in General. (a) Except as otherwise provided in this Section 5.3, each item of income, gain, loss and deduction of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections Section 5.1 and Section 5.2.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Kodiak Gas Services, Inc.), Agreement and Plan of Merger (Kodiak Gas Services, Inc.), Agreement and Plan of Merger (Kodiak Gas Services, Inc.)
Allocations for Tax Purposes in General. (a) Except as otherwise provided in this Section 5.34.3, each item of income, gain, loss loss, deduction, and deduction credit of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections 5.1 Section 4.1 and 5.2Section 4.2.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (TELUS International (Cda) Inc.), Limited Liability Company Agreement (TELUS International (Cda) Inc.)
Allocations for Tax Purposes in General. (a) i. Except as otherwise provided in this Section 5.34.3, each item of income, gain, loss loss, deduction and deduction credit of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections 5.1 Section 4.1 and 5.2Section 4.2.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Stronghold Digital Mining, Inc.), Limited Liability Company Agreement (Stronghold Digital Mining, Inc.)
Allocations for Tax Purposes in General. (ai) Except as otherwise provided in this Section 5.34.2(c) or Section 4.2(d), each item of income, gain, loss and deduction of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections 5.1 4.2(a) and 5.24.2(b).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Brigham Minerals, Inc.), Limited Liability Company Agreement (Brigham Minerals, Inc.)
Allocations for Tax Purposes in General. (a) Except as otherwise provided in this Section 5.3, each item of income, gain, loss loss, deduction and deduction credit of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections Section 5.1 and 5.2.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (ProFrac Holding Corp.), Limited Liability Company Agreement (ProFrac Holding Corp.)
Allocations for Tax Purposes in General. (a) Except as otherwise provided in this Section 5.3, each item of income, gain, loss loss, deduction, and deduction credit of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections Section 5.1 and Section 5.2.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Rice Acquisition Corp. II), Limited Liability Company Agreement (Rice Acquisition Corp. II)
Allocations for Tax Purposes in General. (a) Except as otherwise provided in this Section 5.34.3, each item of income, gain, loss loss, deduction and deduction credit of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections 5.1 Section 4.1 and 5.24.2.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Atlas Energy Solutions Inc.), Limited Liability Company Agreement (Atlas Energy Solutions Inc.)
Allocations for Tax Purposes in General. (a) Except as otherwise provided in this Section 5.3, each item of income, gain, loss and deduction of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections Section 5.1 and 5.2.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Golden Nugget Online Gaming, Inc.), Limited Liability Company Agreement (Landcadia Holdings II, Inc.)
Allocations for Tax Purposes in General. (a) Except as otherwise provided in this Section 5.34.3, each item of income, gain, loss loss, deduction, and deduction credit of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections 5.1 Section 4.1 and 5.24.2.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Rice Acquisition Corp. II), Limited Liability Company Agreement (Archaea Energy Inc.)
Allocations for Tax Purposes in General. (a) Except as otherwise provided in this Section 5.3, each item of income, gain, loss and deduction of the Company for U.S. federal and applicable state and local income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections 5.1 and 5.2.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Appreciate Holdings, Inc.), Business Combination Agreement (Proptech Investment Corp. Ii)
Allocations for Tax Purposes in General. (a) Except as otherwise provided in this Section 5.34.4 , each item of income, gain, loss and deduction of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections 5.1 Section 4.2 and 5.2.Section 4.3 ..
Appears in 1 contract
Samples: Limited Liability Company Agreement (Matlin & Partners Acquisition Corp)
Allocations for Tax Purposes in General. (a) Except as otherwise provided in this Section 5.34.3 or Section 4.4, each item of income, gain, loss and deduction of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections 5.1 4.1 and 5.24.2.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Fortis Minerals, LLC)
Allocations for Tax Purposes in General. (a) Except as otherwise provided in this Section 5.34.3 or Section 4.4, each item of income, gain, loss loss, deduction and deduction credit of the Company for U.S. federal income tax purposes shall be allocated among the Members in the same manner as such item is allocated under Sections 5.1 Section 4.1 and 5.2Section 4.2.
Appears in 1 contract
