754 Election definition

754 Election has the meaning assigned that term in Section 8.02(a)(iii).

AI-Powered Contracts

Draft, Review & Redline at the Speed of AI

754 Election as defined in Section 6.03(a).

754 Election means an election under Section 754 of the Code and any comparable election under any state or local Tax law.

Examples of 754 Election in a sentence

The General Partner shall cause the Partnership to make the Section 754 Election in accordance with applicable regulations thereunder.
Section 2.1. Basis Adjustments and Section 704(c) Allocations; The LLC 754 Election.
Income and deductions of the Partnership that are attributable to the Section 754 Election ("754 allocations") shall be allocated to the Partners entitled thereto.
If such election has no adverse impact --------------------- on any other Member, the Company shall make an election under Section 754 of the Internal Revenue Code (the "754 Election") when requested by a Member.
Any discretion to be exercised by the Company in connection with any adjustments to the Capital Account of a Member following the 754 Election, and the allocation of such adjustment among the assets of the Company, shall be reasonable and determined by the Tax Matters Partner in the exercise of reasonable discretion, after consultation with the Board of Managers and such professional advisors as the Tax Matters Partner considers appropriate.
If at any point the Company or any of its direct or indirect Subsidiaries that is a partnership for U.S. federal income tax purposes does not have a Section 754 Election in effect, the Corporation shall cause the Company or such Subsidiary, as applicable, to make a Section 754 Election at the time that the Company or such Subsidiary, as applicable, files its next U.S. federal income Tax Return.
Federal Income Tax Purposes 37 SECTION 6.6. Effect of Section 754 Election 38 SECTION 6.7. Admissions of Unitholders; Transfers 38 SECTION 6.8. Allocation of Distributions 39 SECTION 6.9. Liability for State and Local and Other Taxes 39 SECTION 6.10.
If, at any point, any Subsidiary of Buyer that is a Partnership does not have a Section 754 Election in effect, Buyer shall cause such Subsidiary of Buyer to make a valid Section 754 Election at the time that such Subsidiary files its Tax Return for such Taxable Year.
The adjustments to basis to Partnership Assets that are attributable to the Section 754 Election shall be allocated to the Partners in the manner that the General Partner determines is reasonable, however, no such adjustment shall be credited or charged to the Capital Accounts.
Purchaser may at any time after the Closing Date, in its sole and absolute discretion, cause MMP and any of the FCC Licensee Entities to make a Code Section 754 Election with respect to the Taxable Period in which the Closing occurs or later Taxable Periods.

More Definitions of 754 Election

754 Election. The election which may be made by the Partnership pursuant to Section 754 of the Code. Securities Act: The Securities Act of 1933, as amended, and the regulations of the Commission promulgated thereunder. Termination Date: December 31, 2085. Transfer Agent: The Depositary or any bank, trust company or other Person (including the General Partner or any of its Affiliates) appointed by the General Partner from time to time, in its sole and absolute discretion, to act as transfer agent for Depositary Units. Unit: A Partnership Interest in the Partnership, other than the General Partner’s Partnership Interest as a General Partner, acquired or issued pursuant to this Agreement, provided that each Unit at any time outstanding shall represent the same fractional part of the Partnership Interests of all Record Holders as each other Unit (unless any class or series of Units issued pursuant to Section 4.05 shall have designations, preferences or special rights such that a Unit of such class or series shall represent a greater or lesser part of the Partnership Interests of all Record Holders than a Unit of any other class or series of Units, in which event the Partnership Interest represented by a Unit of such class or series shall be determined in accordance with such designations, preferences and special rights as are fixed by the General Partner pursuant to Section 4.05 with respect to such class or series of Units). Unit Fraction: With respect to any Record Holder, a fraction, the numerator of which is the number of Depositary Units and held by such Record Holder as of the date of such determination and the denominator of which is the total number of Depositary Units and Units outstanding as of the date of such determination.

754 Election has the meaning set forth in Section 8.4.

754 Election is defined in the recitals.

754 Election shall have the meaning set forth in Section 4.1(d)(ii).