Section 704(c) Allocations. In the event that any property of the Company is credited to the Capital Account of a Member at a value other than its tax basis (whether as a result of a contribution of such property or a revaluation of such property pursuant to clause (b) of the definition of “Gross Asset Value”), then allocations of taxable income, gain, loss and deductions with respect to such property shall be made using any method provided for in Regulation Section 1.704-3.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (J. Alexander's Holdings, Inc.), Limited Liability Company Agreement (J. Alexander's Holdings, Inc.), Limited Liability Company Agreement (J. Alexander's Holdings, Inc.)
Section 704(c) Allocations. In the event that any property of the Company is credited to the Capital Account of a Member at a value other than its tax basis (whether as a result of a contribution of such property or a revaluation of such property pursuant to clause subparagraph (b) of the definition of “Gross Asset Value”), then allocations of taxable income, gain, loss and deductions with respect to such property shall be made using any in accordance with the “traditional” allocation method provided for described in Regulation Section § 1.704-33(b).
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Vantiv, Inc.), Limited Liability Company Agreement (Fifth Third Bancorp), Limited Liability Company Agreement (Vantiv, Inc.)
Section 704(c) Allocations. In the event that any property of the Company is credited to the Capital Account of a Member at a value other than its tax basis (whether as a result of a contribution of such property or a revaluation of such property pursuant to clause (b) of the definition of “Gross Asset Value”), then allocations of taxable income, gain, loss and deductions with respect to such property shall be made using any the traditional method provided for in Regulation Regulations Section 1.704-33(b).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Black Knight, Inc.), Limited Liability Company Agreement (Cannae Holdings, Inc.)
Section 704(c) Allocations. In the event that any property of the Company is credited to the Capital Account of a Member at a value other than its tax basis (whether as a result of a contribution of such property or a revaluation of such property pursuant to clause (b) of the definition of “Gross Asset Value”), then allocations of taxable income, gain, loss and deductions with respect to such property shall be made using any method the “traditional method” provided for in Regulation Section 1.704-33(b).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Black Knight Financial Services, Inc.), Limited Liability Company Agreement (Black Knight Financial Services, Inc.)
Section 704(c) Allocations. In the event that any property of the Company is credited to the Capital Account of a Member at a value other than its tax basis (whether as a result of a contribution of such property or a revaluation of such property pursuant to clause (b) of the definition of “Gross Asset Value”), then allocations of taxable income, gain, loss and deductions with respect to such property shall be made using any method provided for in Regulation Section 1.704-33(b).
Appears in 1 contract
Samples: Limited Liability Company Agreement (J. Alexander's Holdings, Inc.)
Section 704(c) Allocations. In the event that any property of the Company is credited to the Capital Account of a Member at a value other than its tax basis (whether as a result of a contribution of such property or a revaluation of such property pursuant to clause subparagraph (b) of the definition of “Gross Asset Value”), then allocations of taxable income, gain, loss and deductions with respect to such property shall be made using any in accordance with the “traditional” allocation method provided for described in Regulation Section 1.704-33(b).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Total System Services Inc)
Section 704(c) Allocations. In the event that any property of the Company is credited to the Capital Account of a Member at a value other than its tax basis (whether as a result of a contribution of such property or a revaluation of such property pursuant to clause (b) of the definition of “Gross Asset Value”), then allocations of taxable income, gain, loss and deductions with respect to such property shall be made using any reasonable method provided for in Regulation Section 1.704-3as permitted by the Code and the Regulations.
Appears in 1 contract
Section 704(c) Allocations. In the event that any property of the Company is credited to the Capital Account of a Member at a value other than its tax basis (whether as a result of a contribution of such property or a revaluation of such property pursuant to clause (b) of the definition of “Gross Asset Value”), then allocations of taxable income, gain, loss and deductions with respect to such property shall be made using any method provided for in Regulation or methods selected by the Board of Managers that complies with Section 1.704-3704(b) and Section 704(c) of the Code and the Regulations promulgated thereunder (“Section 704(c) Allocations”).
Appears in 1 contract
