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 BOX Holdings asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to §1.704-1(b)(2)(iv)(m)(2) or §1.704-(b)(2)(iv)(m)(4) of the Treasury Regulations, to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of its 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 specially allocated to the Members in a manner consistent with their interests in BOX Holdings in the event that §1.704-1(b)(2)(iv)(m)(2) of the Treasury Regulations applies, or to the member to whom such distribution was made in the event that §1.704-1(b)(2)(iv)(m)(4) of the Treasury Regulations applies.

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

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

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

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any BOX Holdings Company’s asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to §Regulation Section 1.704-1(b)(2)(iv)(m)(2) or §1.704-(b)(2)(iv)(m)(4) of the Treasury RegulationsRegulation Section 1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts Accounts, as the a result of a distribution Distribution to a Member in complete liquidation of his, her or its interest in BOX Holdings, the Company 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 specifically allocated to among the Members in a manner consistent accordance with their interests in BOX Holdings respective Economic Interests in the event that §Regulation Section 1.704-1(b)(2)(iv)(m)(2) of the Treasury Regulations applies, or to the member Members to whom such distribution Distribution was made in the event that §Regulation Section 1.704-1(b)(2)(iv)(m)(4) of the Treasury Regulations applies.

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

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any BOX Holdings asset of the assets of the Company pursuant to Code Section section 734(b) or Code Section section 743(b) is required, pursuant to §Treasury Regulations section 1.704-1(b)(2)(iv)(m)(2) or §1.704-(b)(2)(iv)(m)(4) of the Treasury RegulationsRegulations section 1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution Distribution to a Member in complete liquidation of its interest in BOX Holdingsthat 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 specially allocated to the Members in a manner consistent with proportion to their respective interests in BOX Holdings the Company (as reasonably determined by the Board) in the event that §Treasury Regulations section 1.704-1(b)(2)(iv)(m)(2) of the Treasury Regulations applies, or to the member Member to whom such distribution Distribution was made in the event that §Treasury Regulations section 1.704-1(b)(2)(iv)(m)(4) of the Treasury Regulations applies.

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any BOX Holdings Operating Company asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to §Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(2) or §1.704-(b)(2)(iv)(m)(4) of the Treasury RegulationsRegulations Section l.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the a result of a distribution to a Member in complete liquidation of its interest in BOX Holdingshis 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 specially specifically allocated to the Members in a manner consistent accordance with their interests in BOX Holdings the Operating Company in the event that §Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(2) of the Treasury Regulations applies, or to the member 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) of the Treasury Regulations applies.