Common use of § 754 Adjustments Clause in Contracts

§ 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset under § 734(b) or § 743(b) of the Code is required to be taken into account in determining Capital Accounts under the § 704(b) Regulations, the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under the § 704(b) Regulations.

Appears in 5 contracts

Samples: Operating Agreement (Gci Inc), Operating Agreement (General Communication Inc), Operating Agreement (Liberty Media Corp /De/)

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§ 754 Adjustments. To the extent an adjustment to the adjusted tax ------------------- basis of any Company asset under § (S) 734(b) or § (S) 743(b) of the Code is required to be taken into account in determining Capital Accounts under the § (S) 704(b) Regulations, the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under the § (S) 704(b) Regulations.

Appears in 2 contracts

Samples: Operating Agreement (FLN Finance Inc), Operating Agreement (FLN Finance Inc)

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§ 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset under § ss. 734(b) or § ss. 743(b) of the Code is required to be taken into account in determining Capital Accounts under the § ss. 704(b) Regulations, the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under the § ss. 704(b) Regulations.

Appears in 1 contract

Samples: Reorganization Agreement (General Communication Inc)

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