Certain Special Allocations. All IPCH/Inergy Partners Items shall be allocated to the holders of the Common Units and Class B Units, Pro Rata.
Certain Special Allocations. (i) All Hydrocarbon Items shall be allocated to the Common Unitholders, Pro Rata.
Certain Special Allocations. Notwithstanding Section 3.1(a) and Section 3.1(b), special allocations of Profits, Losses, or specific items of income, gain, loss or deduction may be specially allocated for any Allocation Year as follows:
Certain Special Allocations. Items of income and gain allocated under the foregoing provisions of Section 6.1(d)(i), 6.1(d)(ii), 6.1(d)(iii), 6.1(d)(iv), 6.1(d)(ix) or 6.1(d)(x) that are Hydrocarbon Items shall, to the maximum extent possible, be allocated to the applicable Unitholders other than the holders of Class A Units, Pro Rata.”
Certain Special Allocations. (a) Capital Contributions made by any Partner after the date hereof, and other proceeds from the issuance of securities by the Partnership may, in the sole discretion of the General Partner, be used for the benefit of the Partnership (including, without limitation, the repurchase or redemption of Partnership Interests), or may be distributed by the Partnership, in which case, any such proceeds shall be allocated and distributed among the Partners in accordance with their respective Vested Partnership Points immediately prior to the date of such contribution.
Certain Special Allocations. (a) Capital Contributions made by any Member after the Effective Date, and other proceeds from the issuance of securities by the LLC may, in the sole discretion of the Manager Member, be used for the benefit of the LLC (including, without limitation, the repurchase or redemption of LLC Interests), or, may be distributed by the LLC, in which case, any such proceeds shall be allocated and distributed among the Members in accordance with their respective LLC Points immediately prior to the date of such contribution or issuance of securities; it being understood that in the case the proceeds are a note receivable, any such distribution shall only occur, if at all, upon receipt by the LLC of any cash in respect thereof.
Certain Special Allocations. (a) Capital Contributions made by any Partner after the Effective Date (other than Capital Contributions made pursuant to Section 4.1(c) hereof, which shall be used solely for the purpose or purposes set forth in the Call Notice), and other proceeds from the issuance of securities by the Partnership may, in the sole discretion of the General Partner, be used for the benefit of the Partnership (including, without limitation, the repurchase or redemption of Partnership Interests), or, may be distributed by the Partnership, in which case, any such proceeds shall be allocated and distributed among the Partners in accordance with their respective Partnership Points immediately prior to the date of such contribution; it being understood that in the case the proceeds are a note receivable, any such distribution shall occur upon receipt by the Partnership of any cash in respect thereof.
Certain Special Allocations. The following special allocations shall be made in the following order:
Certain Special Allocations. (a) Capital Contributions made by any Partner after the Effective Date, and other proceeds from the issuance of securities by the Partnership may, in the sole discretion of the General Partner, be used for the benefit of the Partnership (including, without limitation, the repurchase or redemption of Partnership Interests), or, may be distributed by the Partnership, in which case, any such proceeds shall be allocated and distributed among the Partners in accordance with their respective Partnership Points immediately prior to the date of such contribution; it being understood that in the case the proceeds are a note receivable, any such distribution shall occur upon receipt by the Partnership of any cash in respect thereof.
Certain Special Allocations. (a) MINIMUM GAIN CHARGEBACK. Notwithstanding any other provision in this Article IV, if there is a net decrease in Partnership Minimum Gain or Partner Nonrecourse Debt Minimum Gain (determined in accordance with the principles of Treasury Regulations Sections 1.704-2(d) and 1.704-2(i)) during any taxable year, the Members shall be specially allocated items of LLC income and gain for such year (and, if necessary, subsequent years) in an amount equal to their respective shares of such net decrease during such year, determined pursuant to Treasury Regulations Sections 1.704-2(g)(2) and 1.704-2(i)(5). The items to be so allocated shall be determined in accordance with Treasury Regulations Section 1.704-2(f). This Section 4.5(a) is intended to comply with the minimum gain chargeback requirements in such Treasury Regulations Sections and shall be interpreted consistently therewith; including that no chargeback shall be required to the extent of the exceptions provided in Treasury Regulations Sections 1.704-2(f) and 1.704-2(i)(4).
