Common use of Code Section 754 Adjustments Clause in Contracts

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company property 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 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 its Interest, the amount of such adjustment to 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 allocated to the members in accordance with their interests in the Company in the event Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the member to whom such distribution was made in the event Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company property asset pursuant to Code Section 734(b) or Code Section 743(b) is required 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 result of a distribution to a member Member in complete liquidation of his or its Interestinterest in the Company, the amount of such adjustment to 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 Members in accordance with their interests in the Company in the event Regulations Interests if such Section 1.704-1(b)(2)(iv)(m)(2) applies, or or, if such Section 1.704-1(b)(2)(m)(4) applies, to the member Member to whom such distribution was made in the event Regulations Section 1.704-1(b)(2)(iv)(m)(4) appliesmade.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company property asset pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulations Section Sections 1.704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4(4) to be taken into account in determining Capital Accounts as the result of a distribution to a member Member in complete liquidation of its Interestsuch Member’s 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 allocated to the members Members in accordance with their interests in the Company in the event Regulations Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the member Member to whom such distribution was made in the event Regulations that Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(4) applies).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company property asset pursuant to Code Section section 734(b) or Code Section 743(b) is required required, pursuant to Regulations Section section 1.704-1(b)(2)(iv)(m)(2) or 1.704-1.704- 1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a member holder of Financial Rights in complete liquidation of its Interestsuch Financial Rights, 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 holders of Financial Rights in accordance with their interests in the Company in the event that Regulations Section section 1.704-1(b)(2)(iv)(m)(2) applies, or to the member persons to whom such distribution was made in the event that Regulations Section section 1.704-1(b)(2)(iv)(m)(4) applies.. 5.3.8

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company property 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 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 member Partner in complete liquidation of its InterestInterest in accordance with Regulations Sections 1.704-l(b)(2)(iv)(m)(2) or 1.704-l(b)(2)(iv)(m)(4), 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 specifically allocated to the members Partners in accordance with their interests in the Company Partnership in the event Regulations Section 1.704-1(b)(2)(iv)(m)(2l(b)(2)(iv)(m)(2) applies, or to the member Partner to whom such distribution was made in the event Regulations Section 1.704-1(b)(2)(iv)(m)(4l(b)(2)(iv)(m)(4) applies.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any asset of the Company property pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4) (4), to be taken into account in determining Capital Accounts as the a result of a distribution to a member Member in complete liquidation of its Interestinterest in the Company, the amount of such adjustment to the Capital Accounts of the Members 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 Members in accordance with their interests in the Company in the event Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the member Member to whom such distribution distribu-tion was made in the event Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company property asset pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to the Treasury Regulations Section Sections 1.704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4(4) to be taken into account in determining Capital Accounts as the result of a distribution to a member Member in complete liquidation of its Interestsuch Member’s 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 allocated to the members Members in accordance with their interests in the Company in the event Regulations Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the member Member to whom such distribution was made in the event Regulations that Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(4) applies.