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

Tax Allocations; Code Section 704(c). (a) In accordance with Code Section 704(c) and the Treasury Regulations thereunder, income, gain, loss, and deduction with respect to any asset contributed to the capital of the Partnership will, solely for tax purposes, be allocated among the Partners so as to take account of any variation between the adjusted basis of the asset to the Partnership for federal income tax purposes and its initial Carrying Value (computed in accordance with the definition of “Carrying Value” in Section 1.1) using the “remedial allocation method” described in Treasury Regulations Section 1.704-3(d).

Tax Allocations; Code Section 704(c). (a) In accordance with Code Section 704(c) and the Treasury Regulations thereunder, income, gain, loss, and deduction with respect to any asset contributed to the capital of the Partnership Company will, solely for tax purposes, be allocated among the Partners Members so as to take account of any variation between the adjusted basis of the asset to the Partnership Company for federal income tax purposes and its initial Carrying Gross Asset Value (computed in accordance with the definition of “Carrying Gross Asset Value” in Section 1.1”) using the “remedial allocation method” described in Treasury Regulations Section 1.704-3(d).