Code Section 754 Adjustment. To the extent an adjustment to the tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Treas. Reg. Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of the 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 basis) and the gain or loss shall be specially allocated to the Interest Holders in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to that Section of the Regulations.
Appears in 2 contracts
Samples: Limited Partnership Agreement (Corporate Property Associates 15 Inc), Limited Partnership Agreement (Corporate Property Associates 15 Inc)
Code Section 754 Adjustment. To the extent an adjustment to the tax basis of any Partnership Company asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Treas. Reg. Section 1.704-1(b)(2)(iv)(m§ 1.704‑1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of the 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 basis) and the gain or loss shall be specially allocated to the Interest Holders in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to that Section of the Regulations.
Appears in 1 contract
Samples: Limited Liability Company Operating Agreement (Corporate Property Associates 18 Global Inc)
Code Section 754 Adjustment. To the extent an adjustment to the tax --------------------------- basis of any Partnership Company asset pursuant to Code Section 734(b734 (b) or Code Section 743(b743 (b) is required, pursuant to Treas. Reg. Regulation Section 1.704-1(b)(2)(iv)(m1 (b) (2) (iv) (m), to be taken into account in determining Capital Accounts, the amount of the 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 basis) ), and the gain or loss shall be specially allocated to the Interest Holders in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to that Section of the Regulations.
Appears in 1 contract
Code Section 754 Adjustment. To the extent an adjustment to the tax basis of any Partnership company asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Treas. Reg. Regulation Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of the 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 basis) ), and the gain or loss shall be specially allocated to the Economic Interest Holders in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to that Section of the Regulations.
Appears in 1 contract
Code Section 754 Adjustment. To the extent an adjustment to the tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Treas. Reg. Section 1.704-1(b)(2)(iv)(m1(b)(2)(iv) (m), to be taken into account in determining Capital Accounts, the amount of the 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 basis) and the gain or loss shall be specially allocated to the Interest Holders in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to that Section of the Regulations.
Appears in 1 contract
Samples: Limited Partnership Agreement (Corporate Property Associates 15 Inc)
Code Section 754 Adjustment. To the extent an adjustment to the tax basis of any Partnership Company asset pursuant to Code Section 734(b) or Code Section section 743(b) is required, pursuant to Treas. Reg. Section Treasury Regulations section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of the 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 basis) ), and the gain or loss shall be specially allocated to the Interest Holders in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to that Section section of the Treasury Regulations.
Appears in 1 contract
Code Section 754 Adjustment. To the extent an --------------------------- adjustment to the tax basis of any Partnership Company asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Treas. Reg. Regulation Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of the 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 basis) ), and the gain or loss shall be specially allocated to the Interest Holders in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to that Section of the Regulations.
Appears in 1 contract
Samples: Receivables Purchase Agreement (Bethlehem Steel Corp /De/)