Certain Allocations with Respect to Contributed Property. In accordance with Code Section 704(c) and the Treasury Regulations thereunder, items of depreciation, amortization, gain, loss, and deduction with respect to any property contributed to the capital of the LLC 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 LLC for federal income tax purposes and its initial book value, such allocation to be made by the Distribution Committee in its sole discretion in accordance with any method permitted by the applicable Treasury Regulations.
Appears in 3 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement (OM Asset Management PLC), Limited Liability Company Agreement (OM Asset Management LTD)
Certain Allocations with Respect to Contributed Property. In accordance with Code Section 704(c) and the Treasury Regulations thereunder, items of depreciation, amortization, gain, loss, and deduction with respect to any property contributed to the capital of the LLC 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 LLC for federal income tax purposes and its initial book value, such allocation to be made by the Distribution Committee in its sole discretion Manager in accordance with any the so-called "traditional method permitted by with curative allocations solely in the applicable case of a sale of property" as provided under Treasury RegulationsRegulation Section 1.704-3(c)(iii)(B).
Appears in 2 contracts
Samples: Limited Liability Company Operating Agreement (Learningexpress Com Holdings Inc), Limited Liability Company Operating Agreement (Learningexpress Com Holdings Inc)
Certain Allocations with Respect to Contributed Property. In accordance with Code Section 704(c) and the Treasury Regulations thereunder, items of depreciation, amortization, gain, loss, loss and deduction with respect to any property contributed to the capital of the LLC 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 LLC for federal income tax purposes and its initial book value, such allocation to be made by the Distribution Committee in its sole discretion Board of Managers in accordance with any permissible method permitted by the under applicable Treasury Regulations.
Appears in 2 contracts
Samples: Series C Preferred Share Purchase Agreement (China Rapid Finance LTD), Series C Preferred Share Purchase Agreement (China Rapid Finance LTD)
Certain Allocations with Respect to Contributed Property. In accordance with Code Section 704(c) of the Code and the Treasury Regulations thereunder, items of depreciation, amortization, gain, loss, loss and deduction with respect to any property contributed to the capital of the LLC Company shall, solely for tax Tax purposes, be allocated among the Members so as to take account of any variation between the adjusted basis of such property to the LLC Company for federal United States Federal income tax Tax purposes and its initial book value, such allocation to be made by the Distribution Committee in its sole discretion Board of Managers in accordance with any permissible method permitted by the under applicable Treasury Regulations.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Blue Sphere Corp.), Limited Liability Company Agreement (Blue Sphere Corp.)
Certain Allocations with Respect to Contributed Property. In accordance with Code Section 704(c) and the Treasury Regulations thereunder, items of depreciation, amortization, gain, loss, and deduction with respect to any property contributed to the capital of the LLC 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 LLC for federal income tax purposes and its initial book value, such allocation to be made by the Distribution Committee in its sole discretion Board of Managers in accordance with any the so-called "traditional method permitted by with curative allocations solely in the applicable case of a sale of property" as provided under Treasury RegulationsRegulation Section 1.704-3(c)(iii)(B).
Appears in 2 contracts
Samples: Limited Liability Company Operating Agreement (Learningexpress Com Holdings Inc), Limited Liability Company Operating Agreement (Learningexpress Com Holdings Inc)
Certain Allocations with Respect to Contributed Property. In accordance with Code Section 704(c) and the Treasury Regulations thereunder, items of depreciation, amortization, gain, loss, loss and deduction with respect to any property contributed to the capital of the LLC 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 LLC Company for federal income tax purposes and its initial book value, such allocation to be made by the Distribution Committee in its sole discretion Board of Managers in accordance with any permissible method permitted by the under applicable Treasury Regulations.
Appears in 1 contract
