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 of the assets of the Company pursuant to Code section 734(b) or Code section 743(b) is required, pursuant to Treasury Regulations section 1.704-1(b)(2)(iv)(m)(2) or Treasury Regulations section 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 Member in complete liquidation of that Member’s 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 Members in proportion to their respective interests in the Company (as reasonably determined by the Board) in the event Treasury Regulations section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such Distribution was made in the event Treasury 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 of the assets of the Company BOX Holdings asset pursuant to Code section Section 734(b) or Code section Section 743(b) is required, pursuant to Treasury Regulations section §1.704-1(b)(2)(iv)(m)(2) or §1.704-(b)(2)(iv)(m)(4) of the Treasury Regulations section 1.704-1(b)(2)(iv)(m)(4)Regulations, to be taken into account in determining Capital Accounts as the result of a Distribution distribution to a Member in complete liquidation of that Member’s Interestits interest in BOX Holdings, 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 Members in proportion to a manner consistent with their respective interests in the Company (as reasonably determined by the Board) BOX Holdings in the event Treasury Regulations section that §1.704-1(b)(2)(iv)(m)(2) of the Treasury Regulations applies, or to the Member member to whom such Distribution distribution was made in the event Treasury Regulations section 1.704-1(b)(2)(iv)(m)(4) applies.that

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any of the assets of the Operating Company asset pursuant to Code section Section 734(b) or Code section Section 743(b) is required, pursuant to Treasury Regulations section Section 1.704-1(b)(2)(iv)(m)(2) or Treasury Regulations section 1.704Section l.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the a result of a Distribution distribution to a Member in complete liquidation of that Member’s Interesthis 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 Members in proportion to accordance with their respective interests in the Operating Company (as reasonably determined by the Board) in the event Treasury Regulations section Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member Members to whom such Distribution distribution was made in the event that Treasury Regulations section 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 of the assets of the Company Company’s asset pursuant to Code section Section 734(b) or Code section Section 743(b) is required, pursuant to Treasury Regulations section Regulation Section 1.704-1(b)(2)(iv)(m)(2) or Treasury Regulations section Regulation Section 1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts Accounts, as the a result of a Distribution to a Member in complete liquidation of that Member’s Interesthis, her or its interest in the Company 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 among the Members in proportion to accordance with their respective interests in the Company (as reasonably determined by the Board) Economic Interests in the event Treasury Regulations section Regulation Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member Members to whom such Distribution was made in the event Treasury Regulations section that Regulation 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 of the assets of the Company BOX Holdings asset pursuant to Code section Section 734(b) or Code section Section 743(b) is required, pursuant to Treasury Regulations section §1.704-1(b)(2)(iv)(m)(2) or §1.704-(b)(2)(iv)(m)(4) of the Treasury Regulations section 1.704-1(b)(2)(iv)(m)(4)Regulations, to be taken into account in determining Capital Accounts as the result of a Distribution distribution to a Member in complete liquidation of that Member’s Interestits interest in BOX Holdings, 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 Members in proportion to a manner consistent with their respective interests in the Company (as reasonably determined by the Board) BOX Holdings in the event Treasury Regulations section that §1.704-1(b)(2)(iv)(m)(2) of the Treasury Regulations applies, or to the Member member to whom such Distribution distribution was made in the event Treasury Regulations section that §1.704-1(b)(2)(iv)(m)(4) of the Treasury Regulations applies.