Section 754 Election definition

Section 754 Election means an election under Section 754 of the Code and any comparable election under applicable state or local income tax laws.

Section 754 Election shall have the meaning set forth in Section 8.5(a) hereof.

Section 754 Election. An election under Section 754 of the Code relating to the adjustment of the adjusted basis of Partnership Assets as provided in Sections 734 and 743 of the Code.

Examples of Section 754 Election in a sentence

• Any income, gain, loss, or deduction realized as a direct or indirect result of the issuance of an interest in the Company by the Company to a Member (the “Issuance Items”) shall be allocated among the Members so that, to the extent possible, the net amount of such Issuance Items, together with all other allocations under this Agreement to each Member, shall be equal to the net amount that would have been allocated to each such Member if the Issuance Items had not been realized.4.2.4. Section 754 Election.

• However, the language of the K-1 Rule applies only to exclude capital gain reported on the investors’ Schedules K-1, and the Deemed Section 754 Election only applies to sales of QOF interests.Thus, ordinary income from hot assets sold by the QOF or QOZ Business would not be able to be excluded by the investor under either rule.

• This was not done.Finally, even though A, as executrix, followed the revenue ruling in including the stock in the gross estate, nonetheless, we do not believe that, as discussed above, the estate can gain a tax advantage by now disavowing the form of the transaction.For more about the TAM and arguing estate tax inclusion, see fn 5397 in part II.Q.8.e.iii.(b) Transfer of Partnership Interests: Effect on Partnership’s Assets (Section 754 Election or Required Adjustment for Built-in Loss).

• We do not believe that sales of inventory in the ordinary course of a QOZ Business’ trade or business should be excluded under the K-1 Rule or Deemed Section 754 Election.

• The purpose of a Section 754 Election is to reconcile a new partner’s outside and inside basis in the partnership.

More Definitions of Section 754 Election

Section 754 Election has the meaning specified in SECTION 5.6.

Section 754 Election is defined in Section 5.3.1.

Section 754 Election has the meaning provided such term in Section 13.6.

Section 754 Election is defined in the Recitals of this Agreement.

Section 754 Election shall have the meaning specified in Section 4.11(g).

Section 754 Election means any election made by the Partnership under section 754 of the Code.

Section 754 Election means the election described in Section 754 of the Code. “Securities Act” means the Securities Act of 1933.