Allocations for Contributed Property. In accordance with §704(c) of the Code and applicable Treasury Regulations, income, gain, loss and deductions with respect to any property contributed to the Company shall, solely for tax purposes, be allocated among the Members so as to take account of any variation between the adjusted basis of such property to the contributor for federal income tax purposes and its fair market value on the date of its contribution. Allocations pursuant to this Section 3.2 are solely for purposes of federal and state taxes, as appropriate, and shall not affect, or in any way be taken into account, in computing any Member’s capital account or share of profits, losses, or other items or distributions pursuant to any provision of this Agreement.
Appears in 6 contracts
Samples: Operating Agreement (Huntsman Surfactants Technology Corp), Operating Agreement (Huntsman Surfactants Technology Corp), Operating Agreement (Huntsman Surfactants Technology Corp)
