General Allocations of Profits and Losses. Except as otherwise provided in Section 3.4 hereof, items of profit, income, gain, loss, deduction and tax credit recognized by the Company in accordance with the method of accounting and the books and records of the Company as in effect from time to time shall be allocated to and among the Members, prior to any distributions of any Operating Profits attributable thereto, in a manner such that the Capital Account of each Member, immediately after making such allocation, is as nearly as possible equal to the excess of (a) the distributions that would be made to such Member if the Company were dissolved, its affairs wound up and its assets sold for cash equal to their Book Value, all Company liabilities were satisfied (limited with respect to each nonrecourse liability to the fair market value of the assets securing such liability), and the net assets of the Company were distributed pursuant to Section 6.2(a) of this Agreement to the Members immediately after making such allocation, over (b) such Member’s share, if any, of items of Company profit, income, gain, loss, deduction and tax credit specially allocated to such Members pursuant to the provisions of Section 3.4 hereof.
General Allocations of Profits and Losses. Subject to Section 10.3, Profits and Losses of the Company for any Fiscal Year (including, for the avoidance of doubt and in the Board’s sole discretion, any portion of a taxable year) shall be allocated among the Members (i) first, in reverse order to the extent of any net prior allocations of Losses under this Section 10.2 (after taking into account any previous allocations under this Section 10.2(i)), and (ii) second, so that the Capital Account of each Member, after making such allocation, is, as nearly as possible, equal (or in proportion thereto, if the total amount of Profits or Losses available to be allocated is insufficient) to (A) the distributions that would be made to such Member if the Company were dissolved, its affairs wound up, and its assets sold for cash equal to their respective Gross Asset Values, all Company liabilities were satisfied (limited with respect to each nonrecourse liability to the Gross Asset Value of the assets securing such liability), and the remaining assets of the Company were distributed to the Members in accordance with Sections 11.1(ii), (iii) (but excluding the reference to Section 11.1(i)) and (iv) immediately after the hypothetical sale of assets, minus (B) such Member’s share of Company Minimum Gain and Member Minimum Gain, computed immediately before the hypothetical sale of assets; provided, that solely for the purpose of computing the hypothetical distributions under the foregoing clause (A), all outstanding Class C Units shall be treated as if they were Vested Class C Units.
General Allocations of Profits and Losses. Profits, losses, deductions, and credits for any fiscal year shall be allocated to the Members in proportion to their respective Membership Interests. The Company shall provide a summary of all of the members’ profits, losses, and deductions to all of the members.
General Allocations of Profits and Losses. Except as otherwise provided in Section 8.6(b)(ii), Profits and Losses of the Partnership for each Allocation Period shall be allocated to the Partners in accordance with their Percentage Interests.
General Allocations of Profits and Losses. Profits and Losses for any Fiscal Year shall be allocated to the Interest Holders in the ratio of their Participation Percentages. Any deduction attributable to a Non-shared expenses shall be specially allocated to the Member on whose behalf the Firm incurred the Non-shared expense. If any Non Shared Expenses of a Member that are paid or reimbursed by the Firm are not deductible, or are disallowed by the Internal Revenue Service or any other taxing authority as ordinary and necessary business expenses, any additional Firm Profit or income arising from such non-deductibility or disallowance shall be specially allocated to such Member. 9.3
General Allocations of Profits and Losses. Except as otherwise expressly provided in this Agreement, Profits and Losses and, to the extent necessary, individual items of income, gain, loss or deduction of the Company shall be allocated among the Members in a manner such that the Capital Account of each Member, immediately after making such allocation, is, as nearly as possible, equal (proportionately) to (i) the distributions that would be made to such Member pursuant to Section 6.05 (if it were applicable) if the Company were dissolved, its affairs wound up and its assets sold for cash equal to their book value (determined in accordance with section 704(b) of the Code, as implemented by Section 4.04 and Section 6.01 hereof), all Company liabilities were satisfied (limited with respect to each nonrecourse liability to the book value of the assets securing such liability), and the net assets of the Company were distributed in accordance with 6.05 to the Members immediately after making such allocation, minus (ii) such Member’s share of Partnership Minimum Gain and Partner Minimum Gain, computed immediately prior to the hypothetical sale of assets.
General Allocations of Profits and Losses. A. Except as provided in Sections 7.2, 7.3, 7.4 and 7.5 hereof (which shall be applied first), the Profits of the Partnership for each taxable year (or other fiscal period) shall be allocated as follows:
General Allocations of Profits and Losses. Subject to the other provisions of this Article 8, the Profits and Losses of the Company for each Fiscal Year shall be allocated to and shared by the Members in proportion to their Interests.
General Allocations of Profits and Losses. All items of income, gain, deduction and loss of the Company as determined for federal income tax purposes shall be allocated among the Members and shall be credited or debited to their respective Capital Accounts in accordance with Treasury Regulation Section 1.704-1(b)(2)(iv), so as to ensure to the maximum extent possible that such allocations satisfy the economic effect equivalence test of Treasury Regulation Section 1.704- 1(b)(2)(ii)(i). Subject to Section 5.2, net income or net loss (or any items thereof) for each taxable year shall be allocated among the Members’ Capital Accounts pro rata in accordance with their Percentage Interests.
General Allocations of Profits and Losses
