Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.
Appears in 300 contracts
Samples: Partnership Agreement (Crestwood Equity Partners LP), Fourth (Summit Midstream Partners, LP), Agreement
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for U.S. federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.
Appears in 105 contracts
Samples: Agreement, Assignment and Assumption Agreement (USD Partners LP), Contribution and Simplification Agreement (Oasis Midstream Partners LP)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.1.
Appears in 70 contracts
Samples: Agreement and Plan of Redemption and Merger (Markwest Hydrocarbon Inc), Agreement and Plan of Redemption and Merger (Markwest Energy Partners L P), Article Xiv Merger (Enterprise Products Operating L P)
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 2, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.6.1 of the Agreement and Section 1 of this Exhibit C.
Appears in 60 contracts
Samples: Limited Partnership Agreement (Vinebrook Homes Trust, Inc.), Limited Partnership Agreement (NexPoint Real Estate Finance, Inc.), Limited Partnership Agreement (NexPoint Real Estate Finance, Inc.)
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 2, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.1.6.1 of the Agreement and Section 1 of this Exhibit C.
Appears in 56 contracts
Samples: LaSalle Hotel Properties, Gables Realty Limited Partnership, Kite Realty Group Trust
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated allocated, for U.S. federal income tax purposes, among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.
Appears in 29 contracts
Samples: Letter Agreement (Och-Ziff Capital Management Group LLC), Agreement and Plan of Merger (Och-Ziff Capital Management Group LLC), Letter Agreement (Och-Ziff Capital Management Group LLC)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.15.1.
Appears in 26 contracts
Samples: ir-west.enterpriseproducts.com, Agreement (Ferrellgas Partners Finance Corp), Contribution Agreement (Eott Energy Canada Lp)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposesin this Section 6.2, each item of income, gain, loss and deduction that is recognized by the Partnership for federal income tax purposes shall be allocated among the Partners in with reference to the same manner as its correlative item allocations of “book” income, gain, loss or deduction is allocated the corresponding items pursuant to Section 6.1.
Appears in 19 contracts
Samples: EnLink Midstream, LLC, Operating Agreement (EnLink Midstream Partners, LP), Operating Agreement (EnLink Midstream, LLC)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.15.1.
Appears in 16 contracts
Samples: Agreement (Ferrellgas L P), Ferrellgas Partners Finance Corp, Agreement
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Members in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.
Appears in 15 contracts
Samples: Operating Agreement, Limited Liability Company Agreement (Vanguard Natural Resources, LLC), Limited Liability Company Agreement (Vanguard Natural Resources, LLC)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Members in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.1.
Appears in 12 contracts
Samples: Limited Liability Company Agreement (Copano Energy, L.L.C.), Operating Agreement (U S Timberlands Klamath Falls LLC), Limited Liability Company Agreement (Copano Energy, L.L.C.)
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 2, for U.S. federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.6.1 of the Agreement and Section 1 of this Exhibit C.
Appears in 11 contracts
Samples: Agreement (Broad Street Realty, Inc.), Freehold Properties, Inc., Agreement (Pillarstone Capital Reit)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Members in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.14.1.
Appears in 11 contracts
Samples: Limited Liability Company Agreement (Fortress Transportation & Infrastructure Investors LLC), Limited Liability Company Agreement (Fortress Transportation & Infrastructure Investors LLC), Limited Liability Company Agreement (Fortress Transportation & Infrastructure Investors LLC)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Shareholders in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Article IV, Section 6.18.
Appears in 10 contracts
Samples: Trust Agreement, Trust Agreement (Vs Trust), Trust Agreement (Dynamic Shares Trust)
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 2, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.6.01 of the Agreement and Section 1 of this Exhibit C.
Appears in 9 contracts
Samples: Fourth (Gramercy Property Trust Inc.), Gramercy Property Trust Inc., Agreement (Cb Richard Ellis Realty Trust)
Allocations for Tax Purposes. (a) Except as otherwise provided hereinFor Federal, for federal state and local income tax purposes, except as otherwise provided in this Section 5.2, each item of Partnership income, gain, loss and deduction shall be allocated among to the Partners in consistent with the same manner as its correlative item allocations of “book” income, gain, loss or deduction is allocated pursuant to described in Section 6.15.1.
Appears in 9 contracts
Samples: Walton Street Capital Acquisition Co LLC, Walton Street Capital Acquisition Co LLC, Walton Street Capital Acquisition Co LLC
Allocations for Tax Purposes. (a) Except as otherwise provided hereinin this Section 2, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.6.1 of the Agreement and Section 1 of this Exhibit C.
Appears in 9 contracts
Samples: Agreement (STAG Industrial, Inc.), Limited Partnership Agreement (Angel Oak Mortgage, Inc.), Pledge Agreement (NetSTREIT Corp.)
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 2, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.6.1 of the Agreement and Section 1 of this Exhibit B.
Appears in 9 contracts
Samples: Limited Partnership Agreement (Vinebrook Homes Trust, Inc.), Limited Partnership Agreement (Nexpoint Diversified Real Estate Trust), Limited Partnership Agreement (Vinebrook Homes Trust, Inc.)
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 2, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Article 6 of the Agreement and Section 6.1.1 of this Exhibit C.
Appears in 8 contracts
Samples: Crescent Real Estate Equities Co, Crescent Real Estate Equities Co, Crescent Real Estate Equities Co
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Members in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.15.1.
Appears in 8 contracts
Samples: Limited Liability Company Agreement (Vine Energy Inc.), Limited Liability Company Agreement (Vine Energy Inc.), Shareholders Agreement
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.16. 1.
Appears in 7 contracts
Samples: Registration Rights Agreement (Plains All American Pipeline Lp), Plains All American Pipeline Lp, Plains All American Pipeline Lp
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for United States federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.
Appears in 6 contracts
Samples: www.sec.gov, Teekay LNG Partners L.P., Teekay LNG Partners L.P.
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, purposes each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or and deduction is allocated pursuant to Section 6.15.2.
Appears in 6 contracts
Samples: General Partnership Agreement (Colorado Interstate Gas Co), General Partnership Agreement (El Paso Pipeline Partners, L.P.), General Partnership Agreement (Southern Natural Gas Co)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for For federal income tax purposes, except as otherwise provided in this Section 5.2, each item of income, gain, loss loss, deduction and deduction credit of the Partnership shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1accordance with their respective Percentage Interests.
Appears in 6 contracts
Samples: Cedar Fair L P, Cedar Fair L P, Cedar Fair L P
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss loss, deduction and deduction credit shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.
Appears in 6 contracts
Samples: Management Services Agreement (Nextera Energy Partners, Lp), NextEra Energy Partners, LP, NextEra Energy Partners, LP
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss loss, deduction and deduction credit shall be allocated among the Partners Members in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.
Appears in 5 contracts
Samples: Limited Liability Company Agreement (Rattler Midstream Lp), Limited Liability Company Agreement (Rattler Midstream Lp), Limited Liability Company Agreement (Viper Energy Partners LP)
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 2, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Members in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.6.1 of the Agreement and Section 1 of this Exhibit C.
Appears in 5 contracts
Samples: Limited Liability Company Agreement (Welltower OP LLC), Operating Agreement (Broadstone Net Lease, Inc.), Operating Agreement (Broadstone Net Lease, Inc.)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for U.S. federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Members in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.
Appears in 5 contracts
Samples: Limited Liability Company Agreement (Kimbell Royalty Partners, LP), Limited Liability Company Agreement (Kimbell Royalty Partners, LP), Limited Liability Company Agreement (Atlas Energy Group, LLC)
Allocations for Tax Purposes. (a) Except as otherwise provided hereinin this Section 4, for U.S. federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.13.
Appears in 5 contracts
Samples: Trust Agreement (SandRidge Mississippian Trust II), Trust Agreement (SandRidge Mississippian Trust II), Trust Agreement (SandRidge Mississippian Trust II)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Members in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.16.1 and Section 6.2.
Appears in 5 contracts
Samples: Limited Liability Company Agreement (Paulsboro Natural Gas Pipeline Co LLC), Operating Agreement (Sunoco LP), Operating Agreement (Energy Transfer Partners, L.P.)
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 6.6, for U.S. federal and applicable state income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.16.1 and Section 6.5 hereof.
Appears in 4 contracts
Samples: InfraREIT, Inc., InfraREIT, Inc., InfraREIT, Inc.
Allocations for Tax Purposes. (a) Except as otherwise provided hereinin this Agreement, for federal Federal income tax purposes, each any item of Partnership income, gain, loss loss, deduction and deduction credit (and the character and source of such items) shall be allocated among the Partners in the same manner as its correlative the corresponding item of “book” income, gain, loss loss, deduction or deduction credit is allocated to Capital Accounts pursuant to Section 6.1this Article, and the Partnership shall maintain such books, records, and accounts as are necessary to make such allocations.
Appears in 4 contracts
Samples: LyondellBasell F&F Holdco, LLC, Lyondell Refining LP, LLC, Lyondell Refining LP, LLC
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposesin this Section 5.2, each item of income, gain, loss and deduction of the Partnership for federal income tax purposes shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is such items are allocated pursuant to for Capital Account purposes under Section 6.15.1.
Appears in 4 contracts
Samples: Ensource Energy Income Fund LP, Ensource Energy Income Fund LP, Ensource Energy Income Fund LP
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss loss, and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss loss, or deduction is allocated pursuant to Section 6.1.
Appears in 4 contracts
Samples: Joinder Agreement (DCP Midstream, LP), Equity Restructuring Agreement (DCP Midstream, LP), Partnership Agreement (DCP Midstream, LP)
Allocations for Tax Purposes. (a) 4.9.1 Except as otherwise provided hereinin this Section 4.9, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1this Article 4.
Appears in 3 contracts
Samples: Partnership Agreement, Partnership Agreement (Dividend Capital Total Realty Trust Inc.), Partnership Agreement (Dividend Capital Total Realty Trust Inc.)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction which is recognized by the Partnership for federal income tax purposes shall be allocated among the Partners in the same manner as its correlative item of “"book” ," income, gain, loss or deduction is allocated pursuant to Section 6.15.1.
Appears in 3 contracts
Samples: El Paso Energy Partners Lp, Gulfterra Energy Partners L P, El Paso Corp/De
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction which is recognized by the Partnership for federal income tax purposes shall be allocated among the Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.15.1 hereof.
Appears in 3 contracts
Samples: Original Agreement (Felcor Lodging Trust Inc), Original Agreement (Felcor Lodging L P), Original Agreement (Felcor Lodging Trust Inc)
Allocations for Tax Purposes. (a) 5.03(a). Except as otherwise provided herein, for U.S. federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1§ 5.02.
Appears in 3 contracts
Samples: Partnership Agreement (Atlas Growth Partners, L.P.), Partnership Agreement (Atlas Growth Partners, L.P.), Atlas Growth Partners, L.P.
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated allocated, for U.S. federal income tax purposes, among the Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.1.
Appears in 3 contracts
Samples: Och Daniel, Och Daniel, Och Daniel
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “''book” '' income, gain, loss or deduction is allocated pursuant to Section 6.1.
Appears in 3 contracts
Samples: Agreement (Genesis Energy Lp), Enterprise Products Partners L P, Genesis Energy Lp
Allocations for Tax Purposes. (a) Except as otherwise provided hereinin this Section 5.4, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.1Sections 5.1, 5.2 and 5.3 above.
Appears in 3 contracts
Samples: Rights And (American Real Estate Investment Corp), American Real Estate Investment Corp, Keystone Property Trust
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for U.S. federal income tax purposes, each item of income, gain, loss loss, deduction and deduction amount realized shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss loss, deduction or deduction amount realized is allocated pursuant to Section 6.1.
Appears in 3 contracts
Samples: Mach Natural Resources Lp, Mach Natural Resources Lp, TXO Energy Partners, L.P.
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction which is recognized by the Partnership for federal income tax purposes shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.15.1.
Appears in 3 contracts
Samples: www.lw.com, Enbridge Energy Partners Lp, Enbridge Energy Partners Lp
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 2, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.16.1 of the Agreement and Section 1 of this Exhibit "C".
Appears in 3 contracts
Samples: Master Contribution Agreement (Pacific Gulf Properties Inc), Management Agreement (Pacific Gulf Properties Inc), Property Management Agreement (Pacific Gulf Properties Inc)
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 2, for U.S. federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.6.1 of the Agreement and Section 1 of this Exhibit B.
Appears in 3 contracts
Samples: Limited Partnership Agreement (Vinebrook Homes Trust, Inc.), Limited Partnership Agreement (Nexpoint Diversified Real Estate Trust), Limited Partnership Agreement (Vinebrook Homes Trust, Inc.)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated allocated, for U.S. federal income tax purposes, among the Partners Members in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.14.1.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Och-Ziff Capital Management Group LLC), Limited Liability Company Agreement (Och-Ziff Capital Management Group LLC)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss loss, and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.
Appears in 2 contracts
Samples: www.sec.gov, Dorchester Minerals Lp
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Members in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.15.02.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Enterprise Products Partners L P), Limited Liability Company Agreement (Enterprise Products Partners L P)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall which is recognized by the Company for federal income tax purposes will be allocated among the Partners Members in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.15.1.
Appears in 2 contracts
Samples: Acknowledgment and Acceptance Agreement (Enterprise Products Partners L P), Acknowledgment and Acceptance Agreement (El Paso Corp/De)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for U.S. federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Shareholders in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.16.1 hereof.
Appears in 2 contracts
Samples: Trust Agreement (ETFS Collateralized Commodities Trust), Trust Agreement (ETFS Collateralized Commodities Trust)
Allocations for Tax Purposes. (a) Except as otherwise provided hereinin this Section 4.7, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Members in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.14.1 and Section 4.6 hereof.
Appears in 2 contracts
Samples: Company Agreement (InfraREIT, Inc.), Company Agreement (InfraREIT, Inc.)
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 2, for federal federal, state and local income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.1.6.1 of the Agreement and Section 1 of this Exhibit C.
Appears in 2 contracts
Samples: Countryside Square Lp, Hre Properties
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, (i) each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.15.1, and (ii) each tax credit shall be allocated to the Partners in the same manner as the receipt or expenditure giving rise to such credit is allocated pursuant to Section 5.1.
Appears in 2 contracts
Samples: Limited Partnership Agreement (Athlon Energy Inc.), Limited Partnership Agreement (Athlon Energy Inc.)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Members in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1B1.3.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Inergy Storage, Inc.), Limited Liability Company Agreement (Crestwood Midstream Partners LP)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” book income, gain, loss or deduction is allocated pursuant to Section 6.15.2.
Appears in 2 contracts
Samples: Original Agreement (Energy Transfer Equity, L.P.), Original Agreement (Energy Transfer Partners, L.P.)
Allocations for Tax Purposes. (a) Except as otherwise provided hereinin this Section 2, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.5.1 of the Agreement and Section 1 of this Exhibit E.
Appears in 2 contracts
Samples: Limited Partnership Agreement (Sentio Healthcare Properties Inc), Securities Purchase Agreement (Sentio Healthcare Properties Inc)
Allocations for Tax Purposes. (a) i. Except as otherwise provided herein, for U.S. federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1Paragraph 13(a).
Appears in 2 contracts
Samples: Black Stone Minerals, L.P., Black Stone Minerals, L.P.
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Members in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.5J_-
Appears in 2 contracts
Samples: Limited Liability Company Agreement (SilverSun Technologies, Inc.), Limited Liability Company Agreement (SilverSun Technologies, Inc.)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for U.S. federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.16.01.
Appears in 2 contracts
Samples: Exchange Agreement (CNX Resources Corp), CNX Midstream Partners LP
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.15.1 hereof.
Appears in 2 contracts
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 2, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.1.6.1 of the Agreement and Section 1 of this Exhibit B. ---------
Appears in 2 contracts
Samples: Cavanaughs Hospitality Corp, Cavanaughs Hospitality Corp
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for For U.S. federal income tax purposes, except as otherwise provided in this Section 6.4, each item of income, gain, loss loss, deduction and deduction credit of a Fund shall be allocated among the Partners Shareholders in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1accordance with their respective Percentage Interests.
Appears in 2 contracts
Samples: Trust Agreement (Teucrium Commodity Trust), Trust Agreement (Teucrium Commodity Trust)
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 2, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Article 6 of the Agreement and Section 6.1.1 of this Exhibit C.
Appears in 2 contracts
Samples: Crescent Real Estate Equities Co, Crescent Real Estate Equities Co
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 5, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Members in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1Sections 3 and 4 of this Exhibit.
Appears in 2 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement (Armada Oil, Inc.)
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 6, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Members in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.1.6.1 or 6.2 of the Agreement and/or Section 5 of this Exhibit B.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Chelsea Gca Realty Partnership Lp), Limited Liability Company Agreement (Chelsea Gca Realty Inc)
Allocations for Tax Purposes. (ah) Except as otherwise provided hereinin this Section 2, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.6.1 of the Agreement and Section 1 of this Exhibit C.
Appears in 2 contracts
Samples: STAG Industrial, Inc., STAG Industrial, Inc.
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1B1.3.
Appears in 2 contracts
Samples: American Energy Capital Partners - Energy Recovery Program, Lp, American Energy Capital Partners, LP
Allocations for Tax Purposes. (a) 5.2.1 Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction (computed in accordance with Section 4.5.2) is allocated pursuant to Section 6.15.1.
Appears in 2 contracts
Samples: Kaneb Pipe Line Partners L P, Kaneb Pipe Line Partners L P
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, purposes each item of income, gain, loss and deduction shall be allocated among the Partners Members in the same manner as its correlative item of “book” income, gain, loss or and deduction is allocated pursuant to Section 6.15.02.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (El Paso Pipeline Partners, L.P.), Limited Liability Company Agreement (El Paso Pipeline Partners, L.P.)
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 2, for U.S. federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Members in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.6.1 of the Agreement and Section 1 of this Exhibit C.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Nexpoint Diversified Real Estate Trust), Limited Liability Company Agreement (Jernigan Capital, Inc.)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.16. 1.
Appears in 2 contracts
Samples: Williams Energy Partners L P, Plains All American Pipeline Lp
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section Section 6.1.
Appears in 2 contracts
Samples: Exchange Agreement (Delek US Holdings, Inc.), Exchange Agreement (Delek Logistics Partners, LP)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of Partnership income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “Partnership "book” " income, gain, loss or deduction is allocated pursuant to Section 6.15.2.
Appears in 2 contracts
Samples: Bj Services Co, Bj Services Co
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall which is recognized by the Company for federal income tax purposes will be allocated among the Partners Members in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1Sections 6.1 and 6.2.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Boardwalk Pipeline Partners, LP), Limited Liability Company Agreement (Boardwalk Pipeline Partners, LP)
Allocations for Tax Purposes. (a) Except as otherwise provided hereinin this Section 4, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.13.
Appears in 2 contracts
Samples: Trust Agreement (ECA Marcellus Trust I), Trust Agreement (ECA Marcellus Trust I)
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 2, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.1.6.1 of the Agreement and Section 1 of this Exhibit C. ---------
Appears in 2 contracts
Samples: Host Marriott Trust, Host Marriott L P
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for For federal income tax purposes, except as otherwise provided in this Section 3.7, each item of income, gain, loss loss, deduction and deduction credit of the Company shall be allocated among the Partners Members in the same manner as its correlative corresponding item of “"book” " income, gain, loss or deduction is has been allocated pursuant to Section 6.13.6 hereof.
Appears in 1 contract
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.13.
Appears in 1 contract
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 6.5, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.1Sections 6.1 and 6.4 of this Agreement.
Appears in 1 contract
Samples: Agree Realty Corp
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 2, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” book income, gain, loss or deduction is allocated pursuant to Section 6.1.6.1 of the Agreement and Section 1 of this Exhibit C.
Appears in 1 contract
Samples: CNL American Properties Fund Inc
Allocations for Tax Purposes. (a) 4.9.1 Except as otherwise provided hereinin this Section 4.9, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.1this Article 4.
Appears in 1 contract
Samples: Partnership Agreement (Dividend Capital Total Realty Trust Inc.)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for U.S. federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Members in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.1.
Appears in 1 contract
Samples: Recapitalization Agreement (Kimbell Royalty Partners, LP)
Allocations for Tax Purposes. (a) Except as otherwise provided hereinFor federal, for federal state and local income tax purposes, except as otherwise provided in this Section 6.3, each item of the Company’s income, gain, loss, deduction and credit shall be allocated to the Members consistent with the allocations of income, gain, loss loss, deduction and deduction shall be allocated among the Partners credit described in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.16.2.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Empire Petroleum Partners, LP)
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin the Code and Regulations, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.1.6.1 of the Agreement and Section 1 of this Exhibit C.
Appears in 1 contract
Samples: Camden Property Trust
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for U.S. federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.. WESTERN REFINING LOGISTICS, LP FIRST AMENDED AND RESTATED AGREEMENT OF LIMITED PARTNERSHIP
Appears in 1 contract
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Members in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.19.2.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Delek US Holdings, Inc.)
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 6.5, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1Sections 6.1 and 6.4 of this Agreement.
Appears in 1 contract
Allocations for Tax Purposes. (a) Except as otherwise provided hereinin this Section 5.3, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Members in the same manner as its correlative item of “book” book income, gain, loss loss, or deduction is allocated pursuant to Section 6.15.2.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Quest Resource Corp)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for For federal income tax purposes, except as otherwise provided in this Section 5.2, each item of income, gain, loss loss, deduction and deduction credit of the Partnership shall be allocated among the Partners in the same manner as its correlative provided in Section 5.1(a). An allocation to a Partner of Operating Income or Operating Loss shall be treated as an allocation to such Partner of the same share of each item of “book” income, gain, loss and deduction that is taken into account in computing such Operating Income or deduction is allocated pursuant to Section 6.1Operating Loss.
Appears in 1 contract
Samples: FFP Real Estate Trust
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for U.S. federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1.. NORTHERN TIER ENERGY LP FIRST AMENDED AND RESTATED AGREEMENT OF LIMITED PARTNERSHIP
Appears in 1 contract
Samples: Agreement (Northern Tier Energy LP)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss loss, deduction and deduction credit which is recognized by the Company shall be allocated for federal income tax purposes among the Partners Members in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.1Sections 8.3 and 8.4 hereof.
Appears in 1 contract
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss loss, deduction and deduction credit shall be allocated among the Partners Members in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section Section 6.1.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Sunpower Corp)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall which is recognized by the Company for federal income tax purposes will be allocated among the Partners Parties in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.15.1.
Appears in 1 contract
Samples: Performance Guaranty Agreement (Teppco Partners Lp)
Allocations for Tax Purposes. (a) 2.1. Except as otherwise provided hereinin this Section 2, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.1.6.1 of the Agreement and Section 1 of this Exhibit C.
Appears in 1 contract
Samples: Agreement (Monarch Properties Inc)
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 2, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Limited Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.1.6.1 of the Agreement and Section 1 of this Exhibit C.
Appears in 1 contract
Samples: Newkirk Master Lp
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposesin this Section 5.2, each item of income, gain, loss and deduction of the Company for federal income tax purposes shall be allocated among the Partners Members in the same manner as its correlative item of “book” income, gain, loss or deduction is such items are allocated pursuant to for Capital Account purposes under Section 6.15.1.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Ensource Energy Income Fund LP)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Members in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.19.1.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Regency Energy Partners LP)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.1.. ------------
Appears in 1 contract
Samples: Penn Octane Corp
Allocations for Tax Purposes. (a) A. Except as otherwise provided hereinin this Section 2, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Members in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Section 6.1.6.1 of the Agreement and Section 1 of this Exhibit C.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Reckson Operating Partnership Lp)
Allocations for Tax Purposes. (a) Except as otherwise provided herein, for federal income tax purposes, each item of income, gain, loss and deduction shall be allocated among the Partners Members in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Section 6.1Sections 5.1 and 5.2.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Piedmont Natural Gas Co Inc)