Additional Membership Interests. Consistent with the provisions of Treasury Regulation Section 1.704-1(b)(2)(iv)(f), on an issuance of additional Membership Interests for cash or Contributed Property, the Capital Accounts of all Members and the Carrying Value of each Company property immediately prior to such issuance will be adjusted upward or downward to reflect any Unrealized Gain or Unrealized Loss attributable to such Company property, as if such Unrealized Gain or Unrealized Loss had been recognized on an actual sale of each such property immediately prior to such issuance and had been allocated to the Members at such time pursuant to Section 5.1.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Enterprise Products Partners L P), Limited Liability Company Agreement (El Paso Corp/De)
Additional Membership Interests. Consistent with the provisions of Treasury Regulation Section 1.704-1(b)(2)(iv)(fsection 1.7041(b)(2)(iv)(f), on an issuance of additional Membership Interests for cash or Contributed Property, the Capital Accounts of all Members and the Carrying Value of each Company property immediately prior to such issuance will shall be adjusted upward or downward to reflect any Unrealized Gain or Unrealized Loss attributable to such Company property, as if such Unrealized Gain or Unrealized Loss had been recognized on an actual sale of each such property immediately prior to such issuance and had been allocated to the Members at such time pursuant to Section 5.1.
Appears in 1 contract
Samples: Limited Liability Company Agreement (El Paso Energy Partners Lp)
Additional Membership Interests. Consistent with the provisions of Treasury Regulation Section 1.704-section 1.704 1(b)(2)(iv)(f), on an issuance of additional Membership Interests for cash or Contributed Property, the Capital Accounts of all Members and the Carrying Value of each Company property immediately prior to such issuance will shall be adjusted upward or downward to reflect any Unrealized Gain or Unrealized Loss attributable 39 44 to such Company property, as if such Unrealized Gain or Unrealized Loss had been recognized on an actual sale of each such property immediately prior to such issuance and had been allocated to the Members at such time pursuant to Section 5.1.. ADJUSTMENTS PRIOR TO A DISTRIBUTION
Appears in 1 contract
Samples: Limited Liability Company Agreement (El Paso Energy Partners Lp)
