Common use of Section 704(c) Allocations Clause in Contracts

Section 704(c) Allocations. In the event any property of the Company is credited to the Capital Account of a Member at a value other than its Tax basis for U.S. federal income tax purposes (whether as a result of a contribution of such property or a revaluation of such property pursuant to subdivision (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 in a manner which will comply with Section 704(b) and Section 704(c) of the Code and the Regulations thereunder. The Company, in the discretion of the Board of Managers, may make, or not make, “curative” or “remedial” allocations (within the meaning of the Regulations under Section 704(c) of the Code) including, but not limited to:

Section 704(c) Allocations. In the event any property of the Company is credited to the Capital Account of a Member at a value other than its Tax tax basis for U.S. federal income tax purposes (whether as a result of a contribution of such property or a revaluation of such property pursuant to subdivision (b) of the definition of “Gross Asset Value”), then allocations of Taxable taxable income, gain, loss and deductions with respect to such property shall be made in a manner which will comply with Section 704(b) and Section 704(c) of the Code and the Regulations thereunder. The Company, in the discretion of the Board of Managers, may make, or not make, “curative” or “remedial” allocations (within the meaning of the Regulations under Section 704(c) of the Code) including, but not limited to: