Payee Allocation. In the event any payment to any person that is treated by the Company as the payment of an expense is recharacterized by a taxing authority as a Company distribution to the payee as a Unitholder, such payee shall be specially allocated an amount of Company gross income and gain as quickly as possible equal to the amount of the distribution.
Appears in 3 contracts
Sources: Limited Liability Company Agreement (U.S. Shipping Partners L.P.), Limited Liability Company Agreement (U.S. Shipping Partners L.P.), Limited Liability Company Agreement (U.S. Shipping Partners L.P.)
Payee Allocation. In the event any payment to any person that is treated by the Company as the payment of an expense is recharacterized by a taxing authority as a Company distribution to the payee as a UnitholderMember, such payee shall be specially allocated an amount of Company gross income and gain as quickly as possible equal to the amount of the distribution.
Appears in 1 contract
Sources: Limited Liability Company Agreement (Evercore Partners Inc.)
Payee Allocation. In the event any payment to any person Person that is treated by the Company as the a payment of an expense is recharacterized by a taxing authority as a Company distribution to the payee as a UnitholderMember, such payee shall be specially allocated an amount of Company gross income and gain as quickly as possible equal to the amount of the distribution.
Appears in 1 contract
Sources: Limited Liability Company Agreement (China Hydroelectric Corp)