Common use of Allocations for Tax Purposes Clause in Contracts

Allocations for Tax Purposes. Except as otherwise provided in this Section 5.1, the taxable income or loss of the Company (and items thereof) shall be allocated among the Members in the same manner as the corresponding items of Profits and Losses and separate items of income, gain, loss and deduction (excluding items for which there are no related tax items) are allocated among the Members for Capital Account purposes; provided, that, in the case of any Company asset the Gross Asset Value of which differs from its adjusted tax basis for U.S. federal income tax purposes, income, gain, loss and deduction with respect to such asset shall be allocated solely for income tax purposes in accordance with the principles of Section 704(c) of the Code and the Treasury Regulations thereunder (in any manner determined by the Managing Member in its sole discretion that constitutes a “reasonable method,” except as provided in the Tax Protection Agreement) so as to take account of the difference between the Gross Asset Value and the adjusted tax basis of such asset.