Tax Allocations. For each Taxable Year, items of income, deduction, gain, loss, or credit shall be allocated for income tax purposes among the Members in such manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Years (or relevant portions thereof). Allocations under this Section 5.6 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Regulations Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3
Appears in 16 contracts
Sources: Limited Liability Company Agreement (CSFB Alternative Capital Multi-Strategy Master Fund, LLC), Limited Liability Company Agreement (CSFB Alternative Capital Tactical Trading Master Fund, LLC), Limited Liability Company Agreement (Old Field Master Fund, LLC)
Tax Allocations. For each Taxable Yearfiscal year, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members in such manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Years fiscal years (or relevant portions thereof). Allocations under this Section 5.6 5.8 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Regulations Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3
Appears in 7 contracts
Sources: Limited Liability Company Agreement (Oppenheimer Tremont Opportunity Fund LLC), Limited Liability Company Agreement (Oppenheimer Tremont Market Neutral Fund LLC), Limited Liability Company Agreement (Excelsior Low Volatility Hedge Fund of Funds Master Fund LLC)
Tax Allocations. For each Taxable Fiscal Year, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members in such manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Years fiscal years (or relevant portions thereof). Allocations under this Section 5.6 5.7 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Regulations Sections 1.704l.704-1(b)(2)(iv)(fl(b)(2)(iv)(f) and (g), 1.704l.704-1(b)(4)(i) and 1.704-3
Appears in 4 contracts
Sources: Limited Liability Company Agreement (Aetos Long Short Strategies Fund LLC), Limited Liability Company Agreement (Aetos Market Neutral Strategies Fund LLC), Limited Liability Company Agreement (Aetos Distressed Investment Strategies Fund LLC)
Tax Allocations. For each Taxable Yearfiscal year, items of income, deduction, gain, loss, or credit shall be allocated for income tax purposes among the Members in such manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Years fiscal years (or relevant portions thereof). Allocations under this Section 5.6 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Regulations Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3
Appears in 4 contracts
Sources: Limited Liability Company Agreement (Man Glenwood Lexington LLC), Limited Liability Company Agreement (Man Glenwood Tei LLC), Limited Liability Company Agreement (Man Ip 220 LLC)
Tax Allocations. (a) For each Taxable Fiscal Year, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members in such manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Years fiscal years (or relevant portions thereof). Allocations under this Section 5.6 5.9 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Treasury Regulations Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3
Appears in 4 contracts
Sources: Limited Liability Company Agreement (Mercantile Absolute Return Fund LLC), Limited Liability Company Agreement (Mercantile Alternative Strategies Fund LLC), Limited Liability Company Agreement (Mercantile Absolute Return Fund LLC)
Tax Allocations. For each Taxable Fiscal Year, items of income, deduction, gain, loss, or credit shall be allocated for income tax purposes among the Members in such a manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Fiscal Years (or relevant portions thereof). Allocations under this Section 5.6 5.7 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Treasury Regulations Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) ), and 1.704-3
Appears in 4 contracts
Sources: Limited Liability Company Operating Agreement (Mount Yale Opportunity Fund, LLC), Limited Liability Company Operating Agreement (Mount Yale Opportunity Fund, LLC), Limited Liability Company Operating Agreement (Db Hedge Strategies Fund LLC)
Tax Allocations. For each Taxable Fiscal Year, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members in such a manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Fiscal Years (or relevant portions thereof). Allocations under this Section 5.6 5.9 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Treasury Regulations Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3
Appears in 4 contracts
Sources: Limited Liability Company Agreement (Beaumont Fund LLC), Limited Liability Company Agreement (Pw Redwood Fund LLC), Limited Liability Company Agreement (Curan Fund LLC)
Tax Allocations. For each Taxable Yearfiscal year, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members in such manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Years fiscal years (or relevant portions thereof). Allocations under this Section 5.6 5.7 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Regulations Sections 1.704l.704-1(b)(2)(iv)(fl(b)(2)(iv)(f) and (g), 1.704l.704-1(b)(4)(i) and 1.704-3
Appears in 3 contracts
Sources: Limited Liability Company Agreement (Torrey Us Strategy Partners LLC), Limited Liability Company Agreement (Torrey International Strategy Partners LLC), Limited Liability Company Agreement (Torrey Multi Strategy Partners LLC)
Tax Allocations. For each Taxable Yearfiscal year, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members in such manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Years fiscal years (or relevant portions thereof). Allocations under this Section 5.6 5.7 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Regulations Sections 1.704l.704-1(b)(2)(iv)(fl(b)(2)(iv)(f) and (g), 1.704-l.704- 1(b)(4)(i) and 1.704-3
Appears in 3 contracts
Sources: Limited Liability Company Agreement (Torrey International Strategy Partners LLC), Limited Liability Company Agreement (Torrey Us Strategy Partners LLC), Limited Liability Company Agreement (Torrey Multi Strategy Partners LLC)
Tax Allocations. For each Taxable Year, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members in such manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Fiscal Years (or relevant portions thereof). Allocations under this Section 5.6 5.8 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Regulations Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3
Appears in 3 contracts
Sources: Limited Liability Company Agreement (Mezzacappa Multi Strategy Plus Fund LLC), Limited Liability Company Agreement (Mezzacappa Long Short Fund LLC), Limited Liability Company Agreement (Mezzacappa Multi Strategy Fund LLC)
Tax Allocations. For each Taxable Yeartaxable year of the Fund, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members in such a manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Years taxable years (or relevant portions thereof). Allocations under this Section 5.6 5.9 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Treasury Regulations Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3
Appears in 3 contracts
Sources: Limited Liability Company Agreement (Gam Avalon Multi-Global LLC), Limited Liability Company Agreement (Gam Avalon Multi Market Neutral LLC), Limited Liability Company Agreement (Gam Avalon Multi Us LLC)
Tax Allocations. For each Taxable Yeartaxable year of the Fund, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members Partners in such a manner as to reflect equitably amounts credited or debited to each MemberPartner's Capital Account for the current and prior Taxable Years taxable years (or relevant portions thereof). Allocations under this Section 5.6 5.9 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Treasury Regulations Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3
Appears in 3 contracts
Sources: Limited Partnership Agreement (Gam Avalon Multi-Global Lp), Limited Partnership Agreement (Gam Avalon Multi-Europe Lp), Limited Partnership Agreement (Gam Avalon Multi Technology Lp)
Tax Allocations. For each Taxable Yearfiscal year, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members in such manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Years fiscal years (or relevant portions thereof). Allocations under this Section 5.6 5.7 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Treasury Regulations Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3
Appears in 3 contracts
Sources: Limited Liability Company Agreement (Excelsior Multi-Strategy Hedge Fund of Funds (Te 2), LLC), Limited Liability Company Agreement (Excelsior Multi-Strategy Hedge Fund of Funds (Ti 2), LLC), Limited Liability Company Agreement (Excelsior Directional Hedge Fund of Funds (Ti) LLC)
Tax Allocations. (a) For each Taxable Fiscal Year, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members Holders in such manner as to reflect equitably amounts credited or debited to each MemberHolder's Capital Account for the current and prior Taxable Fiscal Years (or relevant portions thereof). Allocations under this Section 5.6 8.10 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Regulations Treasury Regulation Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3
Appears in 2 contracts
Sources: Agreement and Declaration of Trust (Wilmington Low Volatility Fund of Funds), Trust Agreement (Wilmington Low Volatility Fund of Funds)
Tax Allocations. For each Taxable Fiscal Year, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members in such manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Fiscal Years (or relevant portions thereof). Allocations under this Section 5.6 4.8 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Regulations Treasury Regulation Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3
Appears in 2 contracts
Sources: Limited Liability Company Agreement (Bacap Alternative Mult Strategy Fund LLC), Limited Liability Company Agreement (Bacap Alternative Mult Strategy Fund LLC)
Tax Allocations. For each Taxable Fiscal Year, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members in such manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Fiscal Years (or relevant portions thereof). Allocations under this Section 5.6 5.7 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Treasury Regulations Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3
Appears in 2 contracts
Sources: Limited Liability Company Agreement (Grosvenor Registered Multi-Strategy Fund (Te), LLC), Limited Liability Company Agreement (Grosvenor Registered Multi-Strategy Fund (Ti 2), LLC)
Tax Allocations. For each Taxable Year, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members in such manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Fiscal Years (or relevant portions thereof). Allocations under this Section 5.6 5.8 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Treasury Regulations Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3
Appears in 2 contracts
Sources: Limited Liability Company Agreement (Robeco-Sage Multi-Strategy Master Fund, L.L.C.), Limited Liability Company Agreement (Robeco-Sage Triton Master Fund, L.L.C.)
Tax Allocations. For each Taxable Yearfiscal year, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members in such manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Years fiscal years (or relevant portions thereof). Allocations under this Section 5.6 5.10 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, Code and in conformity with Regulations Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3
Appears in 2 contracts
Sources: Limited Liability Company Agreement (Whistler Fund LLC), Limited Liability Company Agreement (Xanthus Fund LLC)
Tax Allocations. For each Taxable Fiscal Year, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members in such manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Fiscal Years (or relevant portions thereof). Allocations under this Section 5.6 4.9 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Regulations Treasury Regulation Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3
Appears in 2 contracts
Sources: Limited Liability Company Agreement (Bacap Alternative Mult Strategy Fund LLC), Limited Liability Company Agreement (Bacap Alternative Mult Strategy Fund LLC)
Tax Allocations. For each Taxable Year, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members in such manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Years fiscal years (or relevant portions thereof). Allocations under this Section 5.6 5.7 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, Code and in conformity with Regulations Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3
Appears in 2 contracts
Sources: Operating Agreement (Acp Continuum Return Fund Ii LLC), Operating Agreement (Acp Strategic Opportunities Fund Ii LLC)
Tax Allocations. For each Taxable Yearfiscal year, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members in such manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Years fiscal years (or relevant portions thereof). Allocations under this Section 5.6 5.8 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Treasury Regulations Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3
Appears in 2 contracts
Sources: Limited Liability Company Agreement (Old Mutual 2100 Emerging Managers Master Fund, L.L.C.), Limited Liability Company Agreement (Old Mutual 2100 Absolute Return Master Fund, L.L.C.)
Tax Allocations. (a) For each Taxable Fiscal Year, items of income, deduction, gain, loss, or credit shall be allocated for income tax purposes among the Members in such a manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Fiscal Years (or relevant portions thereof). Allocations under this Section 5.6 5.7 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Treasury Regulations Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) ), and 1.704-3
Appears in 1 contract
Tax Allocations. For each Taxable Yearfiscal year, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members Partners in such manner as to reflect equitably amounts credited or debited to each MemberPartner's Capital Account for the current and prior Taxable Years fiscal years (or relevant portions thereof). Allocations under this Section 5.6 5.10 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Internal Revenue Code of 1986, as amended (the "Code"), and in conformity with Regulations Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3
Appears in 1 contract
Sources: Limited Partnership Agreement (Wynstone Partners Lp)
Tax Allocations. For each Taxable Yearfiscal year, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members in such manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Years fiscal years (or relevant portions thereof). Allocations under this Section 5.6 5.10 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Regulations Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3
Appears in 1 contract
Sources: Limited Liability Company Agreement (Sawgrass Fund LLC)
Tax Allocations. For each Taxable Yearfiscal year, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members Partners in such manner as to reflect equitably amounts credited or debited to each MemberPartner's Capital Account for the current and prior Taxable Years fiscal years (or relevant portions thereof). Allocations under this Section 5.6 3.09 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Internal Revenue Code of 1986, as amended (the "Code"), and in conformity with Regulations Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3
Appears in 1 contract
Tax Allocations. For each Taxable (a) F▇▇ ▇▇▇▇ Fiscal Year, items of income, deduction, gain, loss, loss or credit shall be allocated for income tax purposes among the Members in such manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior Taxable Years fiscal years (or relevant portions thereof). Allocations under this Section 5.6 5.9 shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Treasury Regulations Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3
Appears in 1 contract
Sources: Limited Liability Company Agreement (Mercantile Small Cap Manager Fund LLC)