Code Section 704(b) Allocations Clause Samples

Code Section 704(b) Allocations. The following special allocations shall be made in the following order and priority:

Code Section 704(b) Allocations. The allocation provisions contained in this Article VI are intended to comply with Code Section 704(b) and the Treasury Regulations promulgated thereunder, and shall be interpreted and applied in a manner consistent therewith.

Code Section 704(b) Allocations. The allocation provisions set forth in Sections 8.3(a), (b) and (c) and 8.4 (the “Regulatory Allocations”) are intended to comply with requirements of Treasury Regulations Sections 1.704 1(b) and 1.704 2. Notwithstanding any other provisions of this Article 8 (other than the Regulatory Allocations), the Regulatory Allocations shall be taken into account as provided for in the following two sentences. Income, gain, loss and deduction shall be reallocated to the extent that such reallocation causes the net aggregate amount of allocations of income, gain, deduction and loss to each Member to be equal to or more closely approximate the net aggregate amount of such items that would have been allocated to each such Member if the Regulatory Allocations had not occurred. This Section 8.5 shall be interpreted and applied in such a manner and to such extent as is reasonably necessary to eliminate, as quickly as possible, permanent economic distortions that would otherwise occur as a consequence of the Regulatory Allocations in the absence of this Section 8.5.