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.
Allocations of Profits and Losses. Unless otherwise required by Code Sections 704(b), 704(c), or Treasury Regulations promulgated thereunder, all Profits, Losses, and items thereof for each fiscal year of the Partnership shall be allocated to the Partners in proportion to their Percentage Interests.
Allocations of Profits and Losses. Except as may otherwise be required by applicable U.S. Treasury regulations (including U.S. Treasury regulations applicable to allocations attributable to Company indebtedness), all profits and losses and all related items of income, gain, loss, deduction, and credit of the Company shall be allocated, charged, or credited among the Members in accordance with their respective membership interests.
Allocations of Profits and Losses. No member shall be given priority or preference with respect to other members in obtaining a return of capital contributions, distributions or allocations of the income, gains, losses, deductions, credits or other items of the LLC. The profits and losses of the LLC, and all items of its income, gain, loss, deduction and credit shall be allocated to members according to each member's percentage interest in this LLC.
Allocations of Profits and Losses. After giving effect to the allocations set forth in, and except as otherwise provided in, Section 5.5, and after adjusting for all Capital Contributions and distributions made during such fiscal year or other period, the Company shall allocate Profit and Loss (and, if necessary, individual items of gross income or loss) for each fiscal year or other period in a manner such that, after such allocations have been made, the balance of each Member’s Capital Account shall, to the extent possible, be equal to an amount that would be distributed to such Member if (a) the Company were to sell the assets of the Company for their book values, (b) all Company liabilities were satisfied (limited with respect to each nonrecourse liability to the book values of the assets securing such liability), (c) the Company were to distribute the proceeds of sale pursuant to Section 6.1(b), and (d) the Company were to dissolve pursuant to Section 10.2(b), minus the sum of (i) such Member’s share of Partnership Minimum Gain or Partner Minimum Gain, and (ii) the amount, if any, that such Member is obligated (or deemed obligated) to contribute, in its capacity as a Member, to the Company, computed immediately prior to the hypothetical sale of assets.
Allocations of Profits and Losses. After giving effect to the special allocations set forth in Section 9.2(b), Profits and Losses (and to the extent determined necessary and appropriate by the Board to achieve the resulting Capital Account balances described below, any allocable items of gross income, gain, loss and expense includable in the computation of Profits and Losses) for each Allocation Period of the Company (including the Allocation Period in which the dissolution or liquidation the Company occurs) shall be allocated among the Members during such Allocation Period, in such a manner as shall cause the Capital Accounts of the Members (as adjusted to reflect all allocations under Section 9.2(b) and all distributions of Available Cash and Special Available Cash, as applicable, through the end of such Allocation Period) to equal, as nearly as possible, (i) the amount such Members would receive if all assets of the Company on hand at the end of such Allocation Period were sold for cash equal to their Carrying Values, all liabilities of the Company were satisfied in cash in accordance with their terms (limited in the case of non-recourse liabilities to the Carrying Value of the property securing such liabilities) and all remaining or resulting cash were distributed to the Members under Sections 9.4(a) (as modified by clause (F) of Schedule 3.1(a), if applicable), 9.4(b) and 9.4(c), minus (b) such Member’s share of Minimum Gain and Member Nonrecourse Debt Minimum Gain, computed immediately prior to the hypothetical sale of assets, and the amount any such Member is treated as obligated to contribute to the Company, computed immediately after the hypothetical sale of assets. In applying the foregoing, Profits and Losses (and items includable therein) attributable to any Special Expansion Project shall, to the maximum extent possible and without altering the aggregate amounts of Profits and Losses otherwise allocable to the Members under this Section 9.2(a), be allocated among the Members in a manner that takes into account each Member’s economic interest with respect to such Special Expansion Project, including, for the avoidance of doubt, such Member’s obligation to make Special Expansion Project Contributions, and such Member’s entitlement to distributions of Special Available Cash, with respect to such Special Expansion Project.
Allocations of Profits and Losses. Except as otherwise provided in this Article VI, Profits and Losses for any Fiscal Period shall be allocated among the Members in such manner that, as of the end of such Fiscal Period, the respective Capital Accounts of the Members shall be equal to the respective amounts that would be distributed to them, determined as if the Company were to (i) liquidate the assets of the Company for an amount equal to their Gross Asset Value and (ii) distribute the proceeds of liquidation pursuant to Section 10.3.