Common use of Code Section 754 Adjustment Clause in Contracts

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or 743(b) is required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Partner in complete liquidation of its interest in the Partnership, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in accordance with their interests in the Partnership in the event Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Partners to whom such distribution was made in the event Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Partnership asset Company property, pursuant to Code Section Sections 734(b) or 743(b) is required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4)) of the Regulations, to be taken into account in determining Capital Accounts as the a result of a distribution to a Partner Member in complete liquidation of its interest in the PartnershipCompany, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially specifically allocated to the Partners Members in accordance with their interests in the Partnership Company (in the event Regulations Section 1.704-1(b)(2)(iv)(m)(2) of the Regulations applies, ) or to the Partners Members to whom such distribution was made (in the event Regulations Section 1.704-1(b)(2)(iv)(m)(4) of the Regulations applies).

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset pursuant to Code Section 734(b) or 743(b) is required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Partner Member in complete liquidation of its interest in the PartnershipCompany, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners Members in accordance with their interests in the Partnership Company in the event Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Partners Members to whom such distribution was made in the event Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset pursuant to Code Section Sections 734(b) or 743(b) is required, required pursuant to Regulations Section Sections 1.704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the a result of a distribution to a Partner in complete liquidation of its interest in the PartnershipCompany, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially specifically allocated to the Partners in accordance with their interests in the Partnership Company (in the event Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, ) or to the Partners to whom such distribution was made (in the event Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies).

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset pursuant to Code Section Sections 734(b) or 743(b) is required, required pursuant to Regulations Section Sections 1.704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the a result of a distribution to a Partner Member in complete liquidation of its interest in the PartnershipUnits, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially specifically allocated to the Partners Members in accordance with their interests in the Partnership Company (in the event Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, ) or to the Partners Members to whom such distribution was made (in the event Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies).

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or 743(b) is required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m)(21(b)(2)(iv)(m) (2) or 1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Partner in complete liquidation of its interest in the Partnership, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in accordance with their interests in the Partnership in the event Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Partners to whom such distribution was made in the event Regulations Section 1.704-1(b)(2)(iv)(m)(41(b)(2)(iv)(m) (4) applies.

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Regulations Sections 1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Partner in complete liquidation of its his interest in the Partnership, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in accordance with their interests in the Partnership in the event Regulations Section 1.704-1(b)(2)(iv)(m)(21.704I (b)(2)(iv)(m)(2) applies, or to the Partners to whom such distribution was made in the event Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset pursuant to Code Section §734(b) or Code §743(b) is required, pursuant to Regulations Section §1.704-1(b)(2)(iv)(m)(2) or Regulations §1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Partner Member in complete liquidation of its his interest in the PartnershipCompany, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners Members in accordance with their the interests in the Partnership Company in the event Regulations Section §1.704-1(b)(2)(iv)(m)(2) applies, or to the Partners Members to whom such distribution was made in the event Regulations Section §1.704-1(b)(2)(iv)(m)(4) applies.

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Section 743(b) is required, required pursuant to Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4), ) of the Regulations to be taken into account in determining Capital Accounts as the result of a distribution to a Partner in complete liquidation of its interest in the PartnershipPartnership Interest, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in accordance with their interests in the Partnership in the event Regulations if Section 1.704-1(b)(2)(iv)(m)(2) of the Regulations applies, or to the Partners Partnership to whom such distribution was made in the event Regulations if Section 1.704-1(b)(2)(iv)(m)(4) of the Regulations applies.

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Partnership asset asset, pursuant to Code Section sections 734(b) or 743(b) is required, pursuant to Regulations Section Regulation sections 1.704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the a result of a distribution to a Partner or Unit Holder in complete liquidation of its interest in the Partnershippartnership interest, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially specifically allocated to the Partners and Unit Holders in accordance with their interests in the Partnership respective right to receive distributions of Net Cash pursuant to Section 4.1 (in the event Regulations Section section 1.704-1(b)(2)(iv)(m)(2) applies, ) or to the Partners Partner or Unit Holder to whom such distribution was made (in the event Regulations Section section 1.704-1(b)(2)(iv)(m)(4) applies).

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset pursuant to Code Section Sections 734(b) or 743(b) is required, required pursuant to Regulations Section 1.704Sections 1. 704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the a result of a distribution to a Partner in complete liquidation of its interest in the PartnershipCompany, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially specifically allocated to the Partners in accordance with their interests in the Partnership Company (in the event Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, ) or to the Partners to whom such distribution was made (in the event Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies).