Book — Tax Accounting Disparities. If the Company Assets are reflected in the Capital Accounts of the Interest Holders at a Gross Asset Value that differs from the adjusted tax basis of such property (whether because such property was contributed to the Company by an Interest Holder or because of a revaluation of the Interest Holders' Capital Accounts under Regulation Section 1.704-1(b)), allocations of depreciation, amortization, income, gain or loss with respect to such property shall be made among the Interest Holders in a manner which takes such difference into account in accordance with Code Section 704(c) and Regulation Section1.704-3(d) using the remedial method.
Appears in 3 contracts
Samples: Operating Agreement (Cinergy Corp), Limited Liability Company Agreement (Cinergy Corp), Limited Liability Company Agreement (Cinergy Corp)
Book — Tax Accounting Disparities. If the Company Assets are reflected in the Capital Accounts of the Interest Holders at a Gross Asset Value that differs from the adjusted tax basis of such property (whether because such property was contributed to the Company by an Interest Holder or because of a revaluation of the Interest Holders' ’ Capital Accounts under Regulation Section 1.704-1(b)), allocations of depreciation, amortization, income, gain or loss with respect to such property shall be made among the Interest Holders in a manner which takes such difference into account in accordance with Code Section 704(c) and Regulation Section1.704Section 1.704-3(d) using the remedial method.
Appears in 1 contract
Samples: Operating Agreement (Cinergy Corp)