Common use of Corrective Allocations Clause in Contracts

Corrective Allocations. The allocations set forth in Section ---------------------- 3.2 (the "Regulatory Allocations") are intended to comply with certain ---------------------- requirements of Sections 1.704-1(b) and 1.704-2 of the Regulations. Notwithstanding any other provision of this Article Three, the Regulatory Allocations shall be taken into account in making allocations of items of income, gain, loss, deduction and expenditure among the Members so that, to the extent possible consistent with the Code and the Regulations and on a cumulative basis, the respective net amounts of such allocations of other items and the Regulatory Allocations to the Members are equal to the respective net amounts that would have been allocated to the Members had no Regulatory Allocations been made. The Managing Member shall apply this Section 3.3 at such times and in whatever order, and shall divide allocations made pursuant to this Section 3.3 among the Members in such manner, as it determines is likely to minimize any economic distortions that might otherwise be caused by the Regulatory Allocations.

Appears in 2 contracts

Samples: Limited Liability Company Agreement (Cmgi Inc), Limited Liability Company Agreement (Cmgi Inc)

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Corrective Allocations. The allocations set forth in Section ---------------------- 3.2 3.3 (the "β€œRegulatory Allocations"”) are intended to comply with certain ---------------------- requirements of Sections 1.704-1(b) and 1.704-2 of the Regulations. Notwithstanding any other provision of this Article Three, the Regulatory Allocations shall be taken into account in making allocations of other items of income, gain, loss, deduction and expenditure among the Members so that, to the extent possible consistent with the Code and the Regulations Regulations, and on a cumulative basis, the respective net amounts of such allocations of other items and the Regulatory Allocations to the Members are equal to the respective net amounts that would have been allocated to the Members had no Regulatory Allocations been made. The Managing Member Members shall apply this Section 3.3 3.4 at such times and in whatever order, and shall divide allocations made pursuant to this Section 3.3 3.4 among the Members in such manner, as it determines is likely to minimize any economic distortions that might otherwise be caused by the Regulatory Allocations.

Appears in 1 contract

Samples: Limited Liability Company Agreement (Geospatial Holdings, Inc.)

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Corrective Allocations. The allocations set forth in Section ---------------------- 3.2 3.3 (the "Regulatory Allocations") are intended to comply with certain ---------------------- requirements of Sections 1.704-1(b) and 1.704-2 of the Regulations. Notwithstanding any other provision of this Article Three, the Regulatory Allocations shall be taken into account in making allocations of items of income, gain, loss, deduction and expenditure among the Members so that, to the extent possible consistent with the Code and the Regulations and on a cumulative basis, the respective net amounts of such allocations of other items and the Regulatory Allocations to the Members are equal to the respective net amounts that would have been allocated to the Members had no Regulatory Allocations been made. The Managing Member shall apply this Section 3.3 3.4 at such times and in whatever order, and shall divide allocations made pursuant to this Section 3.3 3.4 among the Members in such manner, as it determines is likely to minimize any economic distortions that might otherwise be caused by the Regulatory Allocations.

Appears in 1 contract

Samples: Operating Agreement (CMG Information Services Inc)

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