Curative Allocations definition
Curative Allocations means the allocations pursuant to Section 5.05 of this Agreement.
Curative Allocations means allocations pursuant to Section 7.11 of items of income and loss as determined for purposes of maintaining the Capital Accounts.
Curative Allocations means the following allocations of income, gain, loss or deduction. To the extent possible, all Regulatory Allocations shall be offset either with other Regulatory Allocations or with special allocations of other items of company income, gain, loss, or deduction pursuant to this Section. Therefore, notwithstanding any other provision of Section 8 (other than the Regulatory Allocations), such offsetting allocations of income, gain, loss or deduction in whatever manner the Members determine appropriate so that, after such offsetting allocations are made, each Capital Account balance is, to the extent possible, equal to the Capital Account balance such Person would have had if the Regulatory Allocations were not part of this Agreement. In exercising their discretion hereunder, the Members shall take into account future Regulatory Allocations that, although not yet made, are likely to offset other Regulatory Allocations previously made.
Examples of Curative Allocations in a sentence
The allocations in this portion of Section 6.1(d) are a Required Allocation for purposes of the allocation of Curative Allocations in Section 6.1(d).
The limitation on the allocation of Net Termination Loss that is contained in the preceding sentence is a Required Allocation for purposes of the allocation of Curative Allocations in Section 6.1(d).
The limitation on the allocation of Net Loss that is contained in the preceding sentence is a Required Allocation for purposes of the allocation of Curative Allocations in Section 6.1(d).
Accordingly, the Board is authorized to divide other allocations of Profits, Losses, and other items among the Members, to the extent that they exist, so that the net amount of the Regulatory Allocations and the Curative Allocations to each Member is zero.
Accordingly, the Board is authorized to divide other items of income, gain, loss and deduction of the Company among the Members, so that the net amount of the Regulatory Allocations and the Curative Allocations to each Member is zero (0).
More Definitions of Curative Allocations
Curative Allocations means the allocations pursuant to Section 6.3 of this Agreement.
Curative Allocations means the following allocations of income, gain, loss or deduction. Notwithstanding any provision of this Agreement to the contrary, the General Partner shall be authorized to make such other or different allocations of Partnership income, gain, loss or deduction to be specially allocated pursuant to the Regulatory Allocations as the General Partner determines in good faith to be prudent and necessary in order to both: (a) satisfy the applicable provisions of the Code and the Treasury Regulations issued thereunder; and (b) properly reflect and comply with the underlying economic arrangements between the Partners as set forth and described in this Agreement.
Curative Allocations. The allocations set forth in SECTIONS 5.2(b), 5.3(a), 5.3(b), 5.3(c), 5.3(d), 5.3(e), 5.3(f) AND 5.3(g) (the "REGULATORY ALLOCATIONS") are intended to comply with certain requirements of the Regulations. It is the intent of the Partners that, to the extent possible, all Regulatory Allocations shall be offset either with other Regulatory Allocations or with special allocations of other items of Partnership income, gain, loss or deduction pursuant to this SECTION 5.4.
Curative Allocations. The allocations set forth in Paragraphs 10.2 and 10.3 of this Agreement (the "regulatory allocations") are intended to comply with certain requirements of Treasury Regulation Section 1.704-1(b). Notwithstanding any other provisions of this Paragraph 10 (other than the regulatory allocations), the regulatory allocations shall be taken into account in allocating other profits, losses and items of income, gain, loss and deduction among the Partners so that, to the extent possible, the net amount of the allocations of other profits, losses and other items in the regulatory allocations to each Partner shall be equal to the net amount that would have been allocated to each Partner if the regulatory allocations had not occurred. PATR▇▇▇▇ ▇. ▇▇▇▇▇ & ▇SSOCIATES A PROFESSIONAL LAW CORPORATION GENERAL PARTNERSHIP AGREEMENT
Curative Allocations. The allocations set forth in Sections 32(a)-(g) and 18(b) of the Tax Provisions (the “Regulatory Allocations”) are intended to comply with certain requirements of the Regulations. It is in the intent of the Members that, to the extent possible, all Regulatory Allocations shall be offset either with other Regulatory Allocations or with special allocations of other items of Company income, gain, loss or deduction pursuant to this Section 12. Therefore, notwithstanding any other provision of the Tax Provisions (other than the Regulatory Allocations), the Members shall make such offsetting special allocations of Company income, gain, loss, or deduction in whatever manner it (they) determine(s) 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 the Agreement and all Company items were allocated pursuant to Sections 18, 27(a), and 32(h) of the Tax Provisions. In exercising its discretion under this Section 33, the Members shall take into account future Regulatory Allocations under Sections 32(a) and 32(b) that, although not yet made, are likely to offset other Regulatory Allocations previously made under Sections 32(e) and 32(f).
Curative Allocations means the allocations pursuant to Section 5.5 of this Agreement. “Depreciation” means, for each Fiscal Year or other period, an amount equal to the depreciation, amortization or other cost recovery deduction allowable for federal income tax purposes with respect to property for such Fiscal Year or other period, except that (i) with respect to any property the Book Value of which differs from its adjusted tax basis for federal income tax purposes and which difference is being eliminated by use of the “remedial method” pursuant to Treasury Regulation Section l.704-3(d), Depreciation for such taxable year shall be the amount of book basis recovered for such Fiscal Year or other period under the rules prescribed by Treasury Regulation Section l.704-3(d)(2), and (ii) with respect to any other property the Book Value of which differs from its adjusted tax basis at the beginning of such Fiscal Year or other period, Depreciation shall be an amount which bears the same ratio to such beginning Book Value as the federal income tax depreciation, amortization, or other cost recovery deduction for such Fiscal Year or other period bears to such beginning adjusted tax basis; provided that if the adjusted tax basis of any property at the beginning of such Fiscal Year or other period is zero, Depreciation with respect to such property shall be determined with reference to such beginning value using any reasonable method selected by the Board.
Curative Allocations. The allocations set forth in Section 13.2 and 13.3 (the "Regulatory Allocations") are intended to comply with Regulations Section 1.704-1(b), Regulations Section 1.704-2 and Regulations Section 1.704-3, and shall be interpreted and applied in a manner consistent therewith. Notwithstanding any other provisions of this Section (other than the Regulatory Allocations), the Regulatory Allocations shall be taken into account in allocating other profits, losses and items of income, gain, loss and deduction among the Members so that, to the extent possible, the net amount of such allocations of other profits, losses and other items in the Regulatory Allocations to each Member shall be equal to the net amount that would have been allocated to each such Member if the Regulatory Allocations had not occurred.