Common use of Section 754 Clause in Contracts

Section 754. All items of income, gain, loss, deduction and credit recognized by the Company for federal income tax purposes and allocated to the Members in accordance with the provisions hereof shall be determined without regard to any election under section 754 of the Code which may be made by the Company; provided, however, that such allocations, once made, shall be adjusted as necessary or appropriate to take into account those adjustments permitted or required by sections 734 and 743 of the Code.

Appears in 5 contracts

Samples: Limited Liability Company (Williams Partners L.P.), Limited Liability Company Agreement (Williams Partners L.P.), Limited Liability Company Agreement (Williams Partners L.P.)

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Section 754. All For income tax purposes, all items of Company income, gain, loss, loss and deduction allocated and credit recognized by the Company for federal income tax purposes and allocated to shared between or among the Members in accordance with this Exhibit B and all basis allocations to the provisions hereof Members shall first be determined without regard to any election under section Section 754 of the Code which may be made by the CompanyCode; provided, however, that such allocations, once made, shall be adjusted as necessary or appropriate advisable to take into account those the adjustments permitted or required by sections Sections 732, 734 and 743 of the Internal Revenue Code.

Appears in 3 contracts

Samples: Notice, www.dietrichlaw.com, s3.amazonaws.com

Section 754. All items of income, gain, loss, loss and deduction and credit recognized by the Company Partnership for federal income tax purposes and allocated to the Members Partners in accordance with the provisions hereof shall be determined without regard to any election under section Section 754 of the Code which may be made by the CompanyPartnership; provided, however, provided that such allocations, once made, shall be adjusted as necessary or appropriate to take into account those adjustments permitted or required by sections Sections 734 and 743 of the Code.

Appears in 3 contracts

Samples: Agreement of Merger (ServiceMaster Consumer Services Limited Partnership), Merry Maids Limited Partnership, ServiceMaster Consumer Services Limited Partnership

Section 754. All items of income, gain, loss, deduction and credit recognized by the Company for federal income tax purposes and allocated to by the Members in accordance with the provisions hereof shall be determined without regard to any election under section 754 of the Code which may be made by the Company; provided, however, that such allocations, once made, shall be adjusted as necessary or appropriate to take into account those adjustments permitted or required by sections 734 and 743 of the Code.

Appears in 2 contracts

Samples: Limited Liability Company Agreement (DCP Midstream Partners, LP), Limited Liability Company Agreement (DCP Midstream Partners, LP)

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Section 754. All items of income, gain, loss, deduction and credit recognized by the Company for federal income tax purposes and allocated to the Members in accordance with the provisions hereof shall be determined without regard to any election under section Section 754 of the Code which may be made by the Company; provided, however, that such allocations, once made, shall be adjusted as necessary or appropriate to take into account those adjustments permitted or required by sections Sections 734 and 743 of the Code.

Appears in 2 contracts

Samples: Limited Liability Company Agreement (Atlas Pipeline Partners Lp), Limited Liability Company Agreement (Atlas Pipeline Holdings, L.P.)

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