Additional Capital Account Adjustments. Any income of Premier LP that is exempt from federal income tax shall be credited to the Capital Accounts of the Partners in the same manner as Net Profits are credited under Section 5.6 when such income is realized. Any expenses or expenditures of Premier LP which may neither be deducted nor capitalized for tax purposes (or are so treated for tax purposes) shall be charged to the Capital Accounts of the Partners in the same manner as Net Losses are charged under Section 5.6. If Premier LP is subject to an election under Section 754 of the Code or any comparable election under applicable state and local tax law to provide a special basis adjustment upon the transfer of an Interest in Premier LP or the distribution of property by Premier LP, Capital Accounts shall be adjusted to the limited extent required by the Regulations under Section 704 of the Code following any such transfer or distribution.
Appears in 4 contracts
Samples: Limited Partnership Agreement (Premier, Inc.), Indemnification Agreement (Premier, Inc.), Limited Partnership Agreement (Premier, Inc.)
Additional Capital Account Adjustments. Any income of Premier LP the Company that is exempt from federal income tax shall be credited to the Capital Accounts of the Partners Members in the same manner as Net Profits are credited under Section 5.6 when such income is realized. Any expenses or expenditures of Premier LP the Company which may neither be deducted nor capitalized for tax purposes (or are so treated for tax purposes) shall be charged to the Capital Accounts of the Partners Members in the same manner as Net Losses are charged under Section 5.6. If Premier LP the Company is subject to an election under Section 754 of the Code or any comparable election under applicable state and local tax law to provide a special basis adjustment upon the transfer of an Interest in Premier LP the Company or the distribution of property by Premier LPthe Company, Capital Accounts shall be adjusted to the limited extent required by the Regulations under Section 704 of the Code following any such transfer or distribution.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (National Beef, Inc.), Limited Liability Company Agreement (National Beef, Inc.), Limited Liability Company Agreement (National Beef, Inc.)
