Syndication Expenses. Syndication Expenses for any Fiscal Year shall be specially allocated to the Unit Holders in proportion to their Units, provided that, if Units are issued pursuant to Section 2.3 hereof during the Fiscal Year, all Syndication Expenses shall be divided among the Unit Holders from time to time so that, to the extent possible, the cumulative Syndication Expenses allocated with respect to each Unit at any time is the same amount. In the event the Board shall determine that such result is not likely to be achieved through future allocations of Syndication Expenses, the Board may allocate other items of income, gain, deduction, or loss so as to achieve the same effect on the Capital Accounts of the Unit Holders.
Syndication Expenses. 5.3.1 Syndication Expenses, if any, shall be Allocated to the Members pro rata in accordance with their Percentage Interests.
Syndication Expenses. Any syndication expenses which must be deducted from each Member’s Capital Account in accordance with Regulations Section 1.704-l(b)(2)(iv)(i)(2) in the year paid shall be allocated pro rata to the Members based on their Percentage Interest. If Members are admitted to the Company on different dates, all syndication expenses shall be divided among the Members from time to time so that, to the extent possible, the cumulative syndication expenses allocated pursuant to this Section A2(h) with respect to each Unit is the same amount. In the event the Management Committee shall determine that such result is not likely to be achieved through future allocations of syndication expenses, the Management Committee may allocate a portion of Profits or Losses so as to achieve the same effect on the Capital Accounts of the Members, notwithstanding any other provision of this Agreement.
Syndication Expenses. Syndication Expenses for any Fiscal Year or other period shall be allocated to the Members in proportion to their Percentage Interests, provided that if additional Members are admitted to the Company on different dates, all Syndication Expenses shall be divided among those who are Members from time to time so that, to the extent possible the cumulative Syndication Expenses are allocated in proportion to the Percentage Interests from time to time. If the Managing Board determines that such result is not likely to be achieved through future allocations of Syndication Expenses, the Managing Board may allocate a portion of Profits or Losses so as to achieve the same effect on the Capital Accounts of the Members, notwithstanding any other provision of this Agreement.
Syndication Expenses. Except as provided in Section 4.3(f) hereof, Syndication Expenses for any Fiscal Year shall be specially allocated to the Unitholders in proportion to their Units, provided that if Unitholders are admitted to the Partnership on different dates, all Syndication Expenses shall be divided among the Unitholders so that, to the extent possible, the cumulative Syndication Expenses allocated with respect to each Unit at any time is the same amount. In the event that the General Partners determine that such allocation of Syndication Expenses is not likely to be achieved through future allocations of Syndication Expenses, the General Partners may allocate a portion of Profits or Losses so as to achieve the same effect on the Capital Accounts of the Unitholders.
Syndication Expenses. Any syndication expenses which must be deducted from each Member’s Capital Account in accordance with Regulation section 1.704- 1(b)(2)(iv)(i)(2) in the year paid shall be allocated pro rata to the Members based on their Membership Interest. If Members are admitted to the Company on different dates, all syndication expenses shall be divided among the Members from time to time so that, to the extent possible, the cumulative syndication expenses allocated pursuant to this Section A.2(h) with respect to each one percent (1%) of Membership Interest is the same amount. In the event the Board of Managers shall determine that such result is not likely to be achieved through future allocations of syndication expenses, the Board of Managers may allocate a portion of Profits or Losses so as to achieve the same effect on the Capital Accounts of the Members, notwithstanding any other provision of this Agreement.
Syndication Expenses. Regentrealm will on demand pay and reimburse, or procure payment and reimbursement, to the Sole Book Runner and the Arranger, on the basis of a full indemnity, all reasonable out-of-pocket costs and expenses incurred by the Sole Book Runner and the Arranger (and any VAT or other similar tax thereon) in connection with the 2003 Syndication.
Syndication Expenses. All expenditures of the Partnership properly classified as syndication expenses under paragraph (b) of Treas. Regs. sec. 1.709-2. Syndication Expenses shall be taken into account under this Partnership Agreement at the time they would be taken into account under the Partnership's method of accounting if they were deductible expenses for federal income tax purposes.
Syndication Expenses. Section 709 of the Code prohibits a partnership from deducting or amortizing costs that are incurred to promote the sale of partnership interests (i.e., syndication expenses). The Regulations provide definitions for syndication expenses that must be capitalized. Syndication expenses include brokerage fees, registration fees, legal fees for securities advice, accounting fees for preparation of representations to be included in the offering materials, and printing costs of the offering materials. The Partnership intends to treat the entire amount payable to the Sales Agent as a sales commission for selling the Units, as well as certain other fees and expenses allocable to the preparation of this Memorandum and to the offering of the Units in the Partnership, as nondeductible, nonamortizable syndication expenses. Investors will economically bear their respective proportionate share of syndication expenses as these costs likely will be paid out of proceeds from the Offering. These costs will be borne irrespective of their amount, timing and ability of the Partnership to deduct these costs for tax purposes. Management Fee to General Partner. The Partnership pays the General Partner a monthly management fee equal to the greater of $8,000 or 7.5% of Partnership Cash Flow per month. The management fee is paid to the Management Agreement for the time and attention to be devoted by it for supervising and coordinating the management and administration of the Partnership's day-to-day operations pursuant to the terms of the Management Agreement. The Partnership will continue to deduct the management fee in full in the year paid. Assuming the management fee to be paid to the General Partner is ordinary, necessary and reasonable in relation to the services provided, Counsel is of the opinion that the Partnership may deduct the management fee in full in the year paid. State and Local Taxation. Each Investor should consult his or her own attorney or tax advisor regarding the effect of state and other local taxes on his or her personal situation.
Syndication Expenses. In the event that additional Members are admitted to the Company on different dates, all syndication expenses shall be divided among the persons who are Members from time to time so that, to the extent possible, the cumulative amount of syndication expenses allocated with respect to each Member at any time is in proportion to that Member's Percentage Interest as determined after such admission. In the event the Manager shall determine that such result is not likely to be achieved through future allocations of syndication expenses, the Manager may allocate other items of income, gain, deduction or loss so as to achieve the same effect on the Capital Accounts of the Members.
