Common use of Code Section 754 Adjustment Clause in Contracts

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Treasury Regulations Section 1.704-l(b)(2)(iv)3(m)(2) or Treasury Regulations Section 1.704-l(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as a result of a distribution to a Member in complete liquidation of his interest, 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 specifically allocated to the Members in accordance with their interests Operating Agreement for Xxxxxx Quality, LLC in the Company in the event Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or the Members to whom such distribution was made in the event that Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Company BOX Holdings asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Treasury Regulations Section §1.704-l(b)(2)(iv)3(m)(21(b)(2)(iv)(m)(2) or §1.704-(b)(2)(iv)(m)(4) of the Treasury Regulations Section 1.704-l(b)(2)(iv)(m)(4)Regulations, to be taken into account in determining Capital Accounts as a the result of a distribution to a Member in complete liquidation of his interestits interest in BOX Holdings, 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 specifically specially allocated to the Members in accordance a manner consistent with their interests Operating Agreement for Xxxxxx Quality, LLC in the Company BOX Holdings in the event Treasury Regulations Section that §1.704-1(b)(2)(iv)(m)(2) of the Treasury Regulations applies, or to the Members member to whom such distribution was made in the event that Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.that

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Operating Company asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Treasury Regulations Section 1.704-l(b)(2)(iv)3(m)(21(b)(2)(iv)(m)(2) or Treasury Regulations Section 1.704l.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as a result of a distribution to a Member in complete liquidation of his interest, 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 specifically allocated to the Members in accordance with their interests Operating Agreement for Xxxxxx Quality, LLC in the Operating Company in the event Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or the Members to whom such distribution was made in the event that Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(41 (b)(2)(iv)(m)(4) applies.

Code Section 754 Adjustment. To the extent that an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Treasury Regulations Section 1.704-l(b)(2)(iv)3(m)(21(b)(2)(iv)(m)(2) or Treasury Regulations Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as a result of a distribution to a Member in complete liquidation of his such Member’s interest, 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 specifically allocated to the Members in accordance with their interests Operating Agreement for Xxxxxx Quality, LLC in the Company in the event that Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, applies or to the Members to whom such distribution was made in the event that Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.