Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Treasury Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment shall be included as an item of gain (if positive) or loss (if negative) and shall be specially allocated to the Members consistent with the manner in which their Capital Accounts are required to be adjusted by such Treasury Regulation.
Appears in 2 contracts
Sources: Limited Liability Company Agreement (Carbon Natural Gas Co), Limited Liability Company Agreement (Carbon Natural Gas Co)
Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Company asset Asset is required pursuant to Code Sections Section 732(d), Code Section 734(b) ), or Code Section 743(b) is required to be taken into account in determining ), the Capital Accounts under of the Members will be adjusted pursuant to Treasury Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment shall be included as an item of gain (if positive) or loss (if negative) and shall be specially allocated to the Members consistent with the manner in which their Capital Accounts are required to be adjusted by such Treasury Regulation.
Appears in 1 contract
Sources: Limited Liability Company Agreement (NexPoint Real Estate Finance, Inc.)
Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Company asset Property undertaken pursuant to Code Sections Section 734(b) or 743(b) of the Code is required to be taken into account in determining the Capital Accounts of the Members under Treasury Regulations Section 1.7041. 704-1(b)(2)(iv)(m1 (b) (2) (iv) (m), then the amount of such adjustment to the adjustment Capital Accounts shall be included treated as an item of gain (if positive) or loss (if negative) and shall be specially allocated to the Members consistent with adjustment increases the manner in which their Capital Accounts are required to be adjusted by such Treasury Regulation.basis
Appears in 1 contract
Sources: Operating Agreement (Kti Inc)
Section 754 Adjustment. To the extent an any adjustment to the adjusted tax basis of any Company asset of the Partnership pursuant to Code Sections Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulations Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Treasury Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment shall be included treated as an item of gain (if positive) or loss (if negative) and shall be specially allocated to the Members consistent with the manner in which their Capital Accounts are required to be adjusted by such Treasury Regulation.gain
Appears in 1 contract
Sources: Limited Partnership Agreement (Century Communications Corp)
Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Company Fund asset pursuant to Code Sections Section 734(b) or Code Section 743(b) is required permitted pursuant to Treasury Regulation Section 1.704- 1(b)(2)(iv)(m) to be taken into account in determining Capital Accounts under Treasury Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the adjustment shall be included as an item of gain (if positive) or loss (if negative) and shall be specially allocated appropriate adjustments to the Members consistent with the manner in which their Capital Accounts are required to will be adjusted by such Treasury Regulationmade.
Appears in 1 contract
Sources: Limited Partnership Agreement