Reimbursements of Preformation Capital Expenditures. To the extent a distribution (or deemed distribution resulting from a reduction in a Member’s share of Company liabilities for federal tax purposes) otherwise would be treated as proceeds in a sale under Code Section 707(a)(2)(B), the Members intend such actual or deemed distribution to reimburse preformation capital expenditures under Treas. Reg. § 1.707-4(d) to the maximum extent permitted by Law.
Appears in 7 contracts
Samples: Limited Liability Company Agreement (Zeo Energy Corp.), Limited Liability Company Agreement (HNR Acquisition Corp.), Limited Liability Company Agreement (HNR Acquisition Corp.)
Reimbursements of Preformation Capital Expenditures. To the extent a distribution (or deemed distribution resulting from a reduction in a Member’s share of Company liabilities for federal tax purposes) would otherwise would be treated as proceeds in a sale under Code Section section 707(a)(2)(B), the Members intend such actual or deemed distribution to reimburse preformation capital expenditures under Treas. Reg. § 1.707-4(d) to the maximum extent permitted by Law.
Appears in 5 contracts
Samples: Limited Liability Company Agreement (GEN Restaurant Group, Inc.), Limited Liability Company Agreement (Zevia PBC), Limited Liability Company Agreement (Zevia PBC)
Reimbursements of Preformation Capital Expenditures. To the extent a distribution (or deemed distribution resulting from a reduction in a Member’s share of Company liabilities for federal tax purposes) otherwise would be treated as proceeds in a sale under Code Section section 707(a)(2)(B), the Members intend such actual or deemed distribution to reimburse preformation capital expenditures under Treas. Reg. § 1.707-4(d) to the maximum extent permitted by Law.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Rubicon Technologies, Inc.), Limited Liability Company Agreement (NUSCALE POWER Corp), Limited Liability Company Agreement (Spring Valley Acquisition Corp.)
Reimbursements of Preformation Capital Expenditures. To the extent a distribution (or deemed distribution resulting from a reduction in a MemberPartner’s share of Company Partnership liabilities for federal tax purposes) would otherwise would be treated as proceeds in a sale under Code Section section 707(a)(2)(B), the Members Partners intend such actual or deemed distribution to reimburse preformation capital expenditures under Treas. Reg. § 1.707-4(d) to the maximum extent permitted by Law.
Appears in 4 contracts
Samples: Limited Partnership Agreement (StepStone Group Inc.), Transaction Agreement (StepStone Group Inc.), Limited Partnership Agreement (StepStone Group Inc.)
Reimbursements of Preformation Capital Expenditures. To the extent a distribution (or deemed distribution resulting from a reduction in a MemberPartner’s share of Company Partnership liabilities for federal tax purposes) otherwise would be treated as proceeds in a sale under Code Section section 707(a)(2)(B), the Members Partners intend such actual or deemed distribution to reimburse preformation capital expenditures under Treas. Reg. § 1.707-4(d) to the maximum extent permitted by Law.
Appears in 2 contracts
Samples: Limited Partnership Agreement (Excelerate Energy, Inc.), Limited Partnership Agreement (Excelerate Energy, Inc.)
