Common use of Regulatory Allocations Clause in Contracts

Regulatory Allocations. The allocations set forth in Section 5.4(a), Section 5.4(b), Section 5.4(c), Section 5.4(d), Section 5.4(e), Section 5.4(f) and Section 5.4(g) (the “Regulatory Allocations”) are intended to comply with certain requirements of the Treasury Regulations. It is the intent of the Members that, to the extent possible, the Regulatory Allocations shall be offset either with special allocations of other items of Company income, gain, loss, or deduction pursuant to this Section 5.5. Therefore, notwithstanding any other provision of this Article 5 (other than the Regulatory Allocations), the Board shall make such offsetting special allocations of Company income, gain, loss, or deduction in whatever manner it determines appropriate so that, after such offsetting allocations are made, each Member’s Capital Account balance is, to the extent possible, equal to the Capital Account balance such Member would have had if the Regulatory Allocations were not part of this Agreement and all Company items were allocated pursuant to Section 5.3. In exercising its discretion under this Section 5.5, the Board shall take into account future Regulatory Allocations under Section 5.4(a) and Section 5.4(b) that, although not yet made, are likely to offset other Regulatory Allocations previously made under Section 5.4(e) and Section 5.4(f).

Regulatory Allocations. The allocations set forth in Section 5.4(aSections 5.3(a), Section 5.4(b5.3(b), Section 5.4(c5.3(c), Section 5.4(d5.3(d), Section 5.4(e5.3(e), Section 5.4(f5.3(f) and Section 5.4(g5.3(g) (the “Regulatory Allocations”) are intended to comply with certain requirements of the Treasury Regulations. It is the intent of the Members Partners that, to the extent possible, the Regulatory Allocations shall will be offset either with special allocations of other items of Company Partnership income, gain, loss, or deduction pursuant to this Section 5.55.4. Therefore, notwithstanding any other provision of this Article 5 V (other than the Regulatory Allocations), the Board shall make such offsetting special allocations of Company Partnership income, gain, loss, or deduction in whatever manner it determines appropriate will be made so that, after such the offsetting allocations are made, each MemberPartner’s Capital Account balance is, to the extent possible, equal to the Capital Account balance such Member the Partner would have had if the Regulatory Allocations were not part of this Agreement and all Company Partnership items were allocated pursuant to Section 5.35.1, Section 5.2, and Section 5.3 (other than the Regulatory Allocations). In exercising its discretion under this Section 5.55.4, the Board shall General Partner will take into account future Regulatory Allocations under Section 5.4(aSections 5.3(a) and Section 5.4(b5.3(b) that, although not yet made, are likely to offset other Regulatory Allocations previously made under Section 5.4(eSections 5.3(e) and Section 5.4(f5.3(f).

Regulatory Allocations. The allocations set forth in Section 5.4(a), Section 5.4(b), Section 5.4(c), Section 5.4(d), Section 5.4(e), Section 5.4(f) and Section 5.4(g) (the “Regulatory Allocations”) are intended to comply with certain requirements of the Treasury Regulations. It is the intent of the Members that, to the extent possible, the Regulatory Allocations shall be offset either with special allocations of other items of Company income, gain, loss, or deduction pursuant to this Section 5.5. Therefore, notwithstanding any other provision of this Article ARTICLE 5 (other than the Regulatory Allocations), the Board shall make such offsetting special allocations of Company income, gain, loss, or deduction in whatever manner it determines appropriate so that, after such offsetting allocations are made, each Member’s Capital Account balance is, to the extent possible, equal to the Capital Account balance such Member would have had if the Regulatory Allocations were not part of this Agreement and all Company items were allocated pursuant to Section 5.3. In exercising its discretion under this Section 5.5, the Board shall take into account future Regulatory Allocations under Section 5.4(a) and Section 5.4(b) that, although not yet made, are likely to offset other Regulatory Allocations previously made under Section 5.4(e) and Section 5.4(f).

Regulatory Allocations. The allocations set forth in Section 5.4(aSections 5.3(a), Section 5.4(b5.3(b), Section 5.4(c5.3(c), Section 5.4(d5.3(d), Section 5.4(e5.3(e), Section 5.4(f5.3(f) and Section 5.4(g) 5.3(g), and 5.6 (the “Regulatory Allocations”) are intended to comply with certain requirements of the Treasury Regulations. It is the intent of the Members that, to the extent possible, the Regulatory Allocations shall be offset either with special allocations of other items of Company income, gain, loss, or deduction pursuant to this Section 5.5. Therefore, notwithstanding any other provision of this Article 5 V (other than the Regulatory Allocations), the Board Managing Member shall make such offsetting special allocations of Company income, gain, loss, or deduction in whatever manner it determines appropriate so that, after such offsetting allocations are made, each Member’s Capital Account balance is, to the extent possible, equal to the Capital Account balance such Member would have had if the Regulatory Allocations were not part of this Agreement and all Company items were allocated pursuant to Section 5.35.1, Section 5.2, and Section 5.3(h). In exercising its discretion under this Section 5.55.4, the Board Managing Member shall take into account future Regulatory Allocations under Section 5.4(aSections 5.3(a) and Section 5.4(b5.3(b) that, although not yet made, are likely to offset other Regulatory Allocations previously made under Section 5.4(eSections 5.3(e) and Section 5.4(f5.3(f).

Regulatory Allocations. The allocations set forth in Section 5.4(aSections 5.3(a), Section 5.4(b5.3(b), Section 5.4(c5.3(c), Section 5.4(d5.3(d), Section 5.4(e5.3(e), Section 5.4(f5.3(f) and Section 5.4(g) 5.3(g), and 5.5 (the “Regulatory Allocations”) are intended to comply with certain requirements of the Treasury Regulations. It is the intent of the Members that, to the extent possible, the Regulatory Allocations shall be offset either with special allocations of other items of Company income, gain, loss, or deduction pursuant to this Section 5.55.4. Therefore, notwithstanding any other provision of this Article 5 V (other than the Regulatory Allocations), the Board shall make such offsetting special allocations of Company income, gain, loss, or deduction in whatever manner it determines appropriate so that, after such offsetting allocations are made, each Member’s Capital Account balance is, to the extent possible, equal to the Capital Account balance such Member would have had if the Regulatory Allocations were not part of this Agreement and all Company items were allocated pursuant to Section 5.35.1, Section 5.2, and Section 5.3(h). In exercising its discretion under this Section 5.55.4, the Board shall take into account future Regulatory Allocations under Section 5.4(aSections 5.3(a) and Section 5.4(b5.3(b) that, although not yet made, are likely to offset other Regulatory Allocations previously made under Section 5.4(eSections 5.3(e) and Section 5.4(f5.3(f).

Regulatory Allocations. The allocations set forth in Section 5.4(a), Section 5.4(b), Section 5.4(c), Section 5.4(d), Section 5.4(e), Section 5.4(f) and Section 5.4(g) (the “"Regulatory Allocations”") are intended to comply with certain requirements of the Treasury Regulations. It is the intent of the Members that, to the extent possible, the Regulatory Allocations shall be offset either with special allocations of other items of Company income, gain, loss, or deduction pursuant to this Section 5.5. Therefore, notwithstanding any other provision of this Article 5 (other than the Regulatory Allocations), the Board shall make such offsetting special allocations of Company income, gain, loss, or deduction in whatever manner it determines appropriate so that, after such offsetting allocations are made, each Member’s Capital Account balance is, to the extent possible, equal to the Capital Account balance such Member would have had if the Regulatory Allocations were not part of this Agreement and all Company items were allocated pursuant to Section 5.3. In exercising its discretion under this Section 5.5, the Board shall take into account future Regulatory Allocations under Section 5.4(a) and Section 5.4(b) that, although not yet made, are likely to offset other Regulatory Allocations previously made under Section 5.4(e) and Section 5.4(f).

Regulatory Allocations. The allocations set forth in Section 5.4(a), Section 5.4(b), Section 5.4(c), Section 5.4(d), Section 5.4(e), Section 5.4(f5.4 (f) and Section 5.4(g) (the “Regulatory Allocations”) are intended to comply with certain requirements of the Treasury Regulations. It is the intent of the Members that, to the extent possible, the Regulatory Allocations shall be offset either with special allocations of other items of Company income, gain, loss, or deduction pursuant to this Section 5.5. Therefore, notwithstanding any other provision of this Article 5 (other than the Regulatory Allocations), the Board shall make such offsetting special allocations of Company income, gain, loss, or deduction in whatever manner it determines appropriate so that, after such offsetting allocations are made, each Member’s Capital Account balance is, to the extent possible, equal to the Capital Account balance such Member would have had if the Regulatory Allocations were not part of this Agreement and all Company items were allocated pursuant to Section 5.3. In exercising its discretion under this Section 5.5, the Board shall take into account future Regulatory Allocations under Section 5.4(a) and Section 5.4(b) that, although not yet made, are likely to offset other Regulatory Allocations previously made under Section 5.4(e) and Section 5.4(f).