Allocation of Company Items. All items of income, gain, loss, deduction or credit of the Company shall be allocated to Member in proportion to its Company Interests; provided, however, that for federal income tax purposes such items of income, gain, loss and deduction or credit with respect to property contributed by Member to the Company shall be allocated to Member so as to take account of the variation between the federal income tax basis of the property to the Company and its fair market value at the time of its contribution to the Company in accordance with applicable federal tax laws.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (First Wind Holdings Inc.), Limited Liability Company Agreement (First Wind Holdings Inc.)
Allocation of Company Items. All items of income, gain, loss, deduction or credit of the Company shall be allocated to Member among the Members in proportion to its their Company Interestsinterests; provided, however, that for federal income tax purposes such items of income, gain, loss and deduction or credit with respect to property contributed by a Member to the Company shall be allocated to Member between the Members so as to take account of the variation between the federal income tax basis of the property to the Company and its fair market value at the time of its contribution to the Company in accordance with applicable federal tax laws.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Fresh2 Group LTD), Limited Liability Company Agreement