Allocations in General. The Members’ share of tax items, except for Profits and Losses, shall be allocated to the Members pro rata based upon their respective Percentage Interests during the period over which such tax items were accrued. As provided in Section 12.2(b), the Partnership Representative or the Manager shall have authority to make any special allocations for compliance with the provisions of subchapter K of the Code, including without limitation Code Section 704(b) and Code Section 704(c), and the Regulations promulgated thereunder.
Appears in 3 contracts
Sources: Membership Interest Purchase Agreement (Rhove Real Estate 1, LLC), Membership Interest Purchase Agreement (Rhove Real Estate 1, LLC), Asset Purchase Agreement (Rhove Real Estate 1, LLC)