Common use of Allocations Solely for Tax Purposes Clause in Contracts

Allocations Solely for Tax Purposes. Items of income, gain, deduction, loss, and credit for federal income tax purposes shall be allocated among the Members in the same proportions as the corresponding book items are allocated, but if there is a book/tax difference in the determination of any such items by reason of a Member’s contribution of property having a value that varies from its adjusted tax basis, or by reason of any event on account of which assets are marked to market on the Company’s books under the principles of Section 1.704-1(b)(2)(iv)(f) of the Regulations, then such difference shall be reconciled in accordance with the principles of Section 704(c) of the Code and the Regulations thereunder using any permissible method selected by the Manager. Allocations pursuant to this Section 3.3 are solely for tax purposes and shall not affect the Members’ Capital Accounts.

Appears in 2 contracts

Samples: Limited Liability Company Agreement, Limited Liability Company Agreement (Taubman Centers Inc)

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Allocations Solely for Tax Purposes. Items of income, gain, deduction, loss, loss and credit for federal income tax purposes shall be allocated among the Members in the same proportions as the corresponding book items are allocated, but if there is a book/tax difference in the determination of any such items by reason of a Member’s contribution (or deemed contribution) of property having a value that which varies from its adjusted tax basis, or by reason of any event on account of which assets are marked to marked-to-market on the Company’s books book under the principles of Section 1.704-1(b)(2)(iv)(f) of the Regulations, then such difference shall be reconciled in accordance with the principles of Section 704(c) of the Code and the Regulations regulations thereunder using any permissible method selected by the Manager. Allocations Allocation pursuant to this Section 3.3 are solely for tax purposes purposes, and shall not affect the Members’ Capital Accounts.

Appears in 1 contract

Samples: Limited Liability Company Agreement (Taubman Centers Inc)

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Allocations Solely for Tax Purposes. Items of income, gain, deduction, loss, and credit for federal income tax purposes shall be allocated among between the Members in the same proportions as the corresponding book items are allocated, but if there is a book/tax difference in the determination of any such items by reason of a Member’s contribution of property having a value that varies from its adjusted tax basis, or by reason of any event on account of which assets are marked to market on the Company’s books under the principles of Section 1.704-1(b)(2)(iv)(f) of the Regulations, then such difference shall be reconciled in accordance with the principles of Section 704(c) of the Code and the Regulations thereunder using any permissible method selected by the Manager. Allocations pursuant to this Section 3.3 are solely for tax purposes and shall not affect the Members’ Capital Accounts.

Appears in 1 contract

Samples: Limited Liability Company Agreement (Taubman Centers Inc)

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