Tax Allocations; Section 704(c) of the Code. (a) In accordance with Section 704(c) of the Code and the Treasury Regulations thereunder, income, gain, loss and deduction with respect to any property contributed to the capital of the Company shall, solely for income tax purposes, be allocated among the Members so as to take account of any variation between the adjusted basis of such property to the Company for federal income tax purposes and its initial Gross Asset Value (computed in accordance with paragraph (a) of the definition of “Gross Asset Value” contained in Section 1.1 hereof).
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Samples: Limited Liability Company Agreement (Tribune Co), Limited Liability Company Agreement (Tribune Co)
Tax Allocations; Section 704(c) of the Code. (a) In accordance with Section Sec. 704(c) of the Code and the Treasury Regulations thereunder, income, gain, loss and deduction with respect to any property contributed to the capital of the Company shall, solely for income tax purposes, be allocated among to the Members so as to take account of any variation between the adjusted basis of such property to the Company for federal income tax purposes and its initial Gross Asset Value (computed in accordance with paragraph (a) of the definition of “Gross Asset Value” contained in Section 1.1 hereof).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Allegheny Energy Inc)
Tax Allocations; Section 704(c) of the Code. (a) In accordance with Section § 704(c) of the Code and the Treasury Regulations thereunder, income, gain, loss and deduction with respect to any property contributed to the capital of the Company shall, solely for income tax purposes, be allocated among the Members so as to take account of any variation between the adjusted basis of such property to the Company for federal income tax purposes and its initial Gross Asset Value (computed in accordance with paragraph (a) of the definition of “Gross Asset Value” contained in Section 1.1 hereof)fair market value.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Laredo Oil, Inc.)
Tax Allocations; Section 704(c) of the Code. (a) In accordance with Section § 704(c) of the Code and the Treasury Regulations thereunder, income, gain, loss and deduction with respect to any property contributed to the capital of the Company shall, solely for income tax purposes, be allocated among the Members so as to take account of any variation between the adjusted basis of such property to the Company for federal income tax purposes and its initial Gross Asset Value (computed in accordance with paragraph (a) of the definition of “Gross Asset Value” contained in Section 1.1 hereof1.1).
Appears in 1 contract
Samples: Stock Purchase Agreement (Bankatlantic Bancorp Inc)
Tax Allocations; Section 704(c) of the Code. (ai) In accordance with Section §704(c) of the Code and the Treasury Regulations thereunder, income, gain, loss and deduction with respect to any property contributed to the capital of the Company shall, solely for income tax purposes, be allocated among the Members Unit Holders so as to take account of any variation between the adjusted basis of such property to the Company for federal income tax purposes and its initial Gross Asset Value (computed in accordance with paragraph (a) of the definition of “Gross Asset Value” contained in Section 1.1 hereof).
Appears in 1 contract
Samples: Limited Liability Company Operating Agreement (VCI Electronic Coupons, Inc.)
