Allocations Upon Dissolution. If upon dissolution of the Partnership pursuant to Article XVII, and after taking into account all allocations of Net Income and Net Losses (and other tax items) under this Article VIII, distributions, if they were to be made to Unitholders in accordance with their respective Capital Accounts, would result in unequal distributions on their Units, then (i) gross items of income and gain (and other tax items) for the taxable year of final distribution, 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 first to the Class A Unitholders until the Capital Account balance allocable to each Class A Unit is equal, (ii) the same procedure shall be followed with respect to Class B Units until the Capital Account balance allocable to each Class B Unit is equal, and (iii) the same procedure shall be followed with respect to Class B Units until the Capital Account balance allocable to each Class B Unit is equal.
Appears in 2 contracts
Sources: Limited Partnership Agreement (Oppenheimer Capital L P /De/), Agreement of Limited Partnership (Oppenheimer Capital L P /De/)
Allocations Upon Dissolution. If upon dissolution of the Partnership pursuant to Article XVII, and after taking into account all allocations of Net Income and Net Losses Loss (and other tax items) under this Article VIII, distributions, if they were to be made to Unitholders in accordance with their respective Capital Accounts, would result in unequal distributions on their Units, then (i) gross items of income and gain (and other tax items) for the taxable year of final distribution, 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 first to the Class A Unitholders holders of each series of Tracking Units until the Capital Account balance allocable to each Class A Unit of such series is equal, (ii) the same procedure shall be followed with respect to Class B C Units until the Capital Account balance allocable to each Class B C Unit is equal, and (iii) the same procedure shall be followed with respect to Class B A Units until the Capital Account balance allocable to each Class B A Unit is equal.
Appears in 1 contract
Sources: Limited Partnership Agreement (Pimco Advisors Holdings Lp)