Forfeiture Allocations. If any Member forfeits (or has repurchased at less than Fair Market Value) all or a portion of such Member’s Units, the Company shall make forfeiture allocations to such holder in the manner and to the extent required by Proposed Treasury Regulations Section 1.704-1(b)(4)(xii)(c) (as such Proposed Treasury Regulations may be amended or modified, including upon the issuance of temporary or final Treasury Regulations).
Appears in 2 contracts
Sources: Limited Liability Company Agreement (Phoenix Energy One, LLC), Limited Liability Company Agreement (Phoenix Capital Group Holdings, LLC)
Forfeiture Allocations. If any Member forfeits (or has repurchased at less than Fair Market Value) all or a portion of such Member’s Units, the Company shall make forfeiture allocations to such holder in the manner and to the extent required by Proposed Treasury Regulations Regulation Section 1.704-1(b)(4)(xii)(c) (as such Proposed Treasury Regulations Regulation may be amended or modified, including upon the issuance of temporary or final Treasury Regulations)..
Appears in 1 contract
Sources: Framework Agreement (Evolve Transition Infrastructure LP)