Other Special Allocations. The following special allocations shall be made in the following order:
Other Special Allocations. Notwithstanding any other provision of this Section 6.1, the following special allocations shall be made for such taxable period:
Other Special Allocations. (a) If the Company has Net Profits for any Fiscal Year (determined prior to giving effect to this Section 4.03) and the balance of any Member’s Partially Adjusted Capital Account is greater than the balance of its Target Capital Account, then the Member with such excess balance shall be specially allocated items of Company deduction or loss (to the extent available) equal to the difference between its Partially Adjusted Capital Account and its Target Capital Account;
Other Special Allocations. For any Fiscal Year or other taxable period, each Member that makes a contribution described in Section 2.2(b) or 2.3(c) shall be specially allocated items of book gain attributable to the increases in Gross Asset Value of the Company’s assets resulting from such contributions (as such increases are described in Section 2.3A) in an amount equal to the value of such contributions made by such Member.
Other Special Allocations. (i) The Emdeon Members will be specially allocated (pro rata in proportion to their Units) any compensation deduction described in Section 7.09(d)(ii) of the Merger Agreement, and shall be credited with having contributed cash to the Company to fund the equity compensation to which the deduction relates, but for the avoidance of doubt, no such credit shall be given for purposes of calculating the Emdeon Valuation Floor; (ii) if any tax indemnification payment made to the Company pursuant to Section 7.01(a) of the Merger Agreement relates to a tax payment or underlying adjustment that gives rise to a deduction reportable by the Company for income tax purposes, such deduction shall, solely for tax purposes, be specially allocated to the Emdeon Members (in proportion to their Units); (iii) allocations of income or gain shall be allocated to the Emdeon Members (pro rata in proportion to their Units) in the circumstances described in Section 7.09(f); (iv) if any “Loss” described in Section 9.04(c) of the Merger Agreement gives rise to a deduction reportable by the Company for income tax purposes, such deduction shall, solely for income tax purposes, be allocated to the indemnifying party or its Affiliates as described in said Section 9.04(c); and (v) any income attributable to the payment of the Medifax promissory note pursuant to the Mergers will be allocated among the Members in proportion to their Units. Each Member will fully indemnify the other Members against any taxes attributable to income allocated to the indemnifying Member under this subparagraph (h), notwithstanding any reallocation of such income upon audit or otherwise.
Other Special Allocations. The General Partner shall specially allocate to the Partners other than the Investor Common Unitholders (solely with respect to their Investor Units) all items of loss or deduction attributable to any Organization and Offering Expenses (as defined in the Management Agreement) incurred in any Offering (including the Initial Public Offering) to the extent the Manager is, or would be entitled to be (if the Manager had paid such expense rather than the Company or Partnership), reimbursed for such amounts pursuant to Section 9.01(i) of the Management Agreement.
Other Special Allocations. Notwithstanding the provisions of Section 6.3 above, but subject to the provisions of Section 6.4 above, the following allocations shall be made:
Other Special Allocations. In addition to those special allocations specifically described in this Section 5.4, the Company shall make such other special allocations as may be required from time to time by the Code and the Regulations thereunder.
Other Special Allocations. Special allocations shall be made in accordance with the requirements set forth in the Treasury Regulations sections 1.704-2(f), (g) and (j) (minimum gain chargeback), 1.704-2(i)(4) (partner minimum gain chargeback), 1.704-2(i)(2) (nonrecourse deductions), and, to the extent that an election under section 754 of the Code is in effect, 1.704- l(b)(2)(iv)(m) (section 754 adjustments).
