Recapture Items. Any portion of any income or gain attributable to the sale or other disposition of any depreciable Company Property required to be recaptured as ordinary income shall, to the maximum extent possible in accordance with Section 704 of the Code and the Regulations thereunder, be allocated among the Members for tax purposes in the same ratio as the deductions giving rise to such recapture were allocated. Any recapture of tax credit shall be allocated among the Members in accordance with Reg. ss. 1.704-1(b)(4)(ii).
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Sources: Operating Agreement (Public Service Co of Oklahoma), Operating Agreement (Public Service Co of Oklahoma)
Recapture Items. Any portion of any income or gain attributable to the sale or other disposition of any depreciable Company Property property required to be recaptured as ordinary income shall, to the maximum extent possible in accordance with Section 704 of the Code and the Treasury Regulations thereunder, be allocated among the Members for tax Tax purposes in the same ratio as the deductions giving rise to such recapture were allocated. Any recapture of tax Tax credit shall be allocated among the Members in accordance with Reg. ss. Treasury Regulations Section 1.704-1(b)(4)(ii).
Appears in 2 contracts
Sources: Limited Liability Company Agreement (Gatx Corp), Limited Liability Company Agreement (Gatx Corp)
Recapture Items. Any portion of any income or gain attributable to the sale or other disposition of any depreciable Company Property property required to be recaptured as ordinary income shall, to the maximum extent possible in accordance with Section 704 of the Code and the Regulations thereunder, be allocated among the Members for tax purposes in the same ratio as the deductions giving rise to such recapture were allocated. Any recapture of tax credit shall be allocated among the Members in accordance with Reg. ss. §1.704-1(b)(4)(ii).. Table of Contents
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