Change of Trust Interest. Subject to Section 706 of the Code and to any applicable Treasury Regulations, Net Profits, Gross Income, Net Loss, Gross Deductions and items of income, gain, loss, deduction and credit for federal income tax purposes for a Fiscal Year that are attributable to any Ownership Interest that is Transferred or assigned during such Fiscal Year shall be allocated between (i) the portion of the Fiscal Year during which the Ownership Interest in the Trust was held by the Transferor and (ii) the portion of the Fiscal Year during which the Ownership Interest was held by the Transferee on the basis of an interim closing of the books method or any other method chosen by the Board of Managers and permitted under Section 706 of the Code.
Appears in 4 contracts
Samples: Trust Agreement (Medallion Financial Corp), Trust Agreement (Medallion Financial Corp), Trust Agreement (Medallion Financial Corp)
