Mandatory Allocations. Any allocation of Net Income or Net Loss for tax purposes which is required to be allocated among the Shareholders to take into account the disparity between the fair market value of a Trust asset and its adjusted basis (e.g., allocations under Code Section 704(c) for contributed property) shall be allocated among the Shareholders in accordance with the requirements of the Code and the regulations promulgated thereunder.
Appears in 6 contracts
Sources: Trust Agreement (Centerline Holding Co), Trust Agreement (Charter Municipal Mortgage Acceptance Co), Trust Agreement (Chartermac)