Compliance with Section 704. (b) of the Code. The provisions of this Article as they relate to the maintenance of Capital Accounts are intended, and shall be construed, and, if necessary, modified to cause the allocations of profits, losses, income, gains and credits pursuant to this Agreement to have substantial economic effect under the Regulations promulgated under §704(b) of the Code, in view of the distributions and capital contributions made pursuant to this Agreement.
Appears in 2 contracts
Samples: Operating Agreement (Grede Wisconsin Subsidiaries LLC), Operating Agreement (Jernberg Industries, LLC)
Compliance with Section 704. (b) of the Code. .
(a) The provisions of this Article III as they relate to the maintenance of Capital Accounts are intended, and shall be construed, and, if necessary, modified to cause the allocations of profits, losses, income, gains gain and credits credit pursuant to this Agreement Article IV to have substantial economic effect under the Regulations promulgated under §Section 704(b) of the Code, in view light of the distributions made pursuant to Article V and capital contributions the Capital Contributions made pursuant to this AgreementArticle III.
Appears in 1 contract
Samples: Restructuring Agreement (Health Management Associates Inc)
Compliance with Section 704. (b) of the Code. The provisions of this Article Agreement as they relate to the maintenance of Capital Accounts are intended, and shall be construed, and, if necessary, modified to cause the allocations of profits, losses, income, gains and credits pursuant to this Agreement to have substantial economic effect under the Regulations promulgated under §704(b) of the Code, in view of the distributions and capital contributions made pursuant to this Agreement.
Appears in 1 contract
Samples: Operating Agreement