Ameliorative Allocations. The term “Regulatory Allocations” shall mean the allocations set forth in Section 5.4(a) through Section 5.4(h). Offsetting special allocations of Company income, gain, loss or deduction shall be made so that, after such offsetting allocations are made, each Partner’s Capital Account is, to the extent possible, equal to the Capital Account such Partner would have had if the Regulatory Allocations were not included in this Agreement. For this purpose, future Regulatory Allocations under Section 5.4(a) and Section 5.4(b) that are likely to offset current Regulatory Allocations under Section 5.4(e) and Section 5.4(f) shall be taken into account.
Appears in 4 contracts
Samples: Limited Partnership Agreement, Partnership Agreement, Limited Liability Limited Partnership Agreement (Strategic Hotel Capital Inc)
