Section 704(c). In accordance with Section 704(c) of the Code and the applicable Treasury Regulations thereunder, income, gain, loss, deduction and tax depreciation with respect to any property contributed to the capital of the Company, or with respect to any property which has a Gross Asset Value different than its adjusted tax basis, shall, solely for federal income tax purposes, be allocated among the Members so as to take into account any variation between the adjusted tax basis of such property to the Company and the Gross Asset Value of such property.
Appears in 1 contract
Sources: Limited Liability Company Agreement (New Home Co Inc.)
Section 704(c). In accordance with Section 704(c) of the Code and the applicable Treasury Regulations thereunder, income, gain, loss, loss and deduction and tax depreciation with respect to any property contributed to the capital of the Company, or with respect to any property which has a Gross Asset Value different than its adjusted tax basis, Company shall, solely for federal income tax purposes, be allocated among the Members so as to take into account of any variation between the adjusted tax basis of such property to the Company for federal income tax purposes and the Gross Asset Value of such propertyits initial fair market value.
Appears in 1 contract
Sources: Limited Liability Company Operating Agreement (Coca-Cola Consolidated, Inc.)
Section 704(c). In accordance with Code Section 704(c) of the Code and the applicable Treasury Regulations thereunder, income, gain, loss, deduction and tax depreciation expense with respect to any property contributed to the capital of the Company, or with respect to any property which has a Gross Asset Value different than its adjusted tax basis, Company shall, solely for federal income tax purposes, be allocated among the Members so as to take into account of any variation between the adjusted tax basis of such property to the Company for federal income tax purposes and its fair market value at the Gross Asset Value time of such propertycontribution. The Company shall use the "traditional method" without curative allocations as described in Treasury Regulation Section 1.704-3(b).
Appears in 1 contract