Recapture Income. Any gain allocated to the Members upon the sale or other taxable disposition of any Company asset shall, to the extent possible, after taking into account other required allocations of gain pursuant to this Section 4.2 be characterized as Recapture Income in the same proportions and the same extent as such Members (or their predecessors in interest) have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 5 contracts
Samples: Limited Liability Company Agreement (DCP Midstream Partners, LP), Purchase and Sale Agreement (Williams Partners L.P.), Limited Liability Company Agreement (Williams Partners L.P.)
Recapture Income. Any gain allocated to the Members upon the sale or other taxable disposition of any Company asset shall, to the extent possible, reasonably practicable after taking into account other required allocations of gain pursuant to this Section 4.2 Sections 4.6 and 4.7, be characterized as Recapture Income in the same proportions and to the same extent as such Members (or their predecessors in interest) have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 2 contracts
Samples: Company Agreement (InfraREIT, Inc.), Company Agreement (InfraREIT, Inc.)
Recapture Income. Any gain allocated to the Members upon the sale or other taxable disposition of any Company asset Asset shall, to the extent possible, after taking into account other required allocations of gain pursuant to this Section 4.2 be characterized as Recapture Income in the same proportions and the same extent as such Members (or their predecessors in interest) have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Atlas Pipeline Partners Lp), Limited Liability Company Agreement (Atlas Pipeline Holdings, L.P.)
Recapture Income. Any gain allocated to the Members upon the sale or other taxable disposition of any Company asset shall, to the extent possible, after taking into account other required allocations of gain pursuant to this Section 4.2 be characterized as Recapture Income in the same proportions and the same extent as such Members (or their predecessors in interest) have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Incomeincome.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (ONEOK Partners LP), Limited Liability Company (Williams Partners L.P.)
Recapture Income. Any gain allocated to the Members upon the sale or other taxable disposition of any Company asset shall, to the extent possible, possible after taking into account other required allocations of gain pursuant to this Section 4.2 5.1(c), be characterized as Recapture Income in the same proportions and to the same extent as such Members (or their predecessors in interest) have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 1 contract
Samples: Operating Agreement (StartEngine Real Estate REIT 1 LLC)
