BASIS ADJUSTMENT UNDER SECTION 754. To the extent an adjustment to the adjusted tax basis of any Company assets pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain, if the adjustment increases the basis of the asset, or loss, if the adjustment decreases such basis, and such gain or loss shall be specially allocated to the Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Regulations.
Appears in 4 contracts
Sources: Limited Liability Company Agreement (Behringer Harvard Opportunity REIT I, Inc.), Limited Liability Company Agreement (Behringer Harvard Opportunity REIT I, Inc.), Limited Liability Company Agreement (Behringer Harvard Opportunity REIT I, Inc.)