Special Tax Allocations. The allocations in this Section 6.9 shall be given effect before giving effect to the allocations contained in Sections 6.1 through Section 6.5:
Special Tax Allocations. The following special allocations shall be made in the following order:
Special Tax Allocations. Items of income, gain, loss, expense or credit resulting from a Covered Audit Adjustment shall be allocated to the Partners in accordance with the applicable provisions of the Partnership Audit Tax Rules.
Special Tax Allocations. Notwithstanding any other provision to the contrary in this Agreement, the following provisions shall apply:
Special Tax Allocations. Notwithstanding any other provision of this Article VII, the following special allocations shall be made in the following order:
Special Tax Allocations. (a) Allocations of tax credits, tax credit recapture, and any items related thereto (unless otherwise agreed to by the Members) shall be allocated to the Members in accordance with the Sharing Percentages or as otherwise agreed to by all of the Members.
Special Tax Allocations. 19 Section 7.05.
Special Tax Allocations. In accordance with Code § 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any property contributed to the capital of the Company (including, but not limited to, the Property) shall, solely for tax purposes, be allocated among the Members so as to take account of any variation between the adjusted basis of such property to the Company for federal income tax purposes and its initial Book Value (computed in accordance with the definition of Book Value) using the "remedial method" as described in Regulations promulgated under Code § 704(c). In the event the Book Value of any Company asset is adjusted pursuant to subparagraph (ii) of the definition of Book Value, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Book Value in the same manner as under Code § 704(c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Executive Committee in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 5.4 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Member's Capital Account or share of Profits, Losses, other items, or distributions pursuant to any provision of this Agreement.
Special Tax Allocations. (a) Qualified Income Offset. In the event any Partner unexpectedly ----------------------- receives any adjustments, allocations, or distributions described in Regulations Section 1.704-1 (b)(2)(ii)(d)(4),(5), or (6), items of Partnership income and gain shall be specially allocated to each such Partner in an amount and manner sufficient to eliminate, to the extent required by the Regulations, the Adjusted Capital Account Deficit of such Partner as quickly as possible, provided that an allocation pursuant to this Section 1(a) shall be made if and only to the extent that such Partner would have an Adjusted Capital Account Deficit after all other allocations provided for in Article VI hereof have been tentatively made as if this Section 1(a) were not in the Agreement.
Special Tax Allocations. Other Allocation Rules; Tax Allocations: Code Section 704(c)...............9 6.4 Allocations in the Event of Transfer................................................................9 6.5
