Common use of Section 754 Adjustment Clause in Contracts

Section 754 Adjustment. To the extent that an adjustment to the adjusted tax basis of any Partnership asset is required under Code Section 734(b) or 743(b) in connection with a distribution to a Partner in complete liquidation of such Partner's interest in the Partnership and the resultant redetermination pursuant to Regulations Section 1.704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4) of the Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis), and such gain or loss shall be allocated pro rata to the remaining Partners in accordance with their respective Partnership Interests in the event Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Partner to which such distribution was made in the event that Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustment. To the extent that an adjustment to the adjusted tax basis of any Partnership asset is required under Code Section 734(b) or 743(b) in connection with a distribution to a Partner in complete liquidation of such Partner's interest in the Partnership and the resultant redetermination pursuant to Regulations Section 1.704-1(b)(2)(iv)(m)(2l(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4l(b)(2)(iv)(m)(4) of the Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis), and such gain or loss shall be allocated pro rata to the remaining Partners in accordance with their respective Partnership Interests in the event Regulations Section 1.704-1(b)(2)(iv)(m)(2l(b)(2)(iv)(m)(2) applies, or to the Partner to which such distribution was made in the event that Regulations Section 1.704-1(b)(2)(iv)(m)(4l(b)(2)(iv)(m)(4) applies.