Common use of Code Section 704(c) Allocations Clause in Contracts

Code Section 704(c) Allocations. (a) 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 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 Company for federal income tax purposes and its initial Gross Asset Value computed in accordance with the definition of “Gross Asset Value” using such method as the Managing Member or the Board, as applicable, shall select.

Code Section 704(c) Allocations. (a) 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 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 Company for federal income tax purposes and its initial Gross Asset Value computed in accordance with the definition of “Gross Asset Value” using such method as the Managing Member or the Board, as applicable, shall select.

Code Section 704(c) Allocations. (a) In Notwithstanding any other provision in this Section 8, in accordance with Code Section 704(c) and the Treasury Regulations promulgated thereunder, income, gain, loss, and deduction with respect to any property contributed to the capital of 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 Company for federal income tax purposes and its initial Gross Asset Value computed in accordance with fair market value on the definition date of “Gross Asset Value” using such method as the Managing Member or the Board, as applicable, shall selectcontribution.