Allocations for Contributed Property Clause Samples
Allocations for Contributed Property. In accordance with §704(c) of the Code and applicable Treasury Regulations, income, gain, loss and deductions with respect to any property contributed to the Company shall, solely for tax purposes, be allocated among the Members so as to take account of any variation between the adjusted basis of such property to the contributor for federal income tax purposes and its fair market value on the date of its contribution. Allocations pursuant to this Section 3.2 are solely for purposes of federal and state taxes, as appropriate, and shall not affect, or in any way be taken into account, in computing any Member’s capital account or share of profits, losses, or other items or distributions pursuant to any provision of this Agreement.
Allocations for Contributed Property. Notwithstanding the above, if Company property is revalued pursuant to Income Tax Regulations Section 1.704-1(b) (2) (iv) (f) or (g), items of depreciation, amortization and gain or loss, as computed for tax purposes with respect to Company property, shall be determined and allocated to the Members so as to take account of the variation between the adjusted tax basis and book value of such property in the same manner as under Section 704(c) of the Internal Revenue Code.
Allocations for Contributed Property. In accordance with Code Section 704(c) and the Treasury Regulations thereunder, income, gain, loss, and deduction with respect to any property contributed to the capital of the Partnership shall, solely for tax purposes, be allocated among the Partners in a manner consistent with Code Section 704(c) and the Treasury Regulations thereunder. In the event the fair market value of any Partnership property is adjusted due to a distribution of property, admission of a new Partner, termination of the Partnership or otherwise, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall be allocated among the Partners in the same manner consistent with Code Section 704(c) and the Treasury Regulations thereunder.