Compliance with Treasury Regulations. The provisions of this Agreement, as amended, relating to the maintenance of Capital Accounts are intended to comply with Treasury Regulation Section 1.704-1(b), and must be interpreted and applied in a manner consistent with those Treasury Regulations. If the Tax Matters Partner determines that it is prudent to modify the manner in which the Capital Accounts, or any debits or credits thereto, are computed to comply with those Treasury Regulations, the Tax Matters Partner may make such modification, if it is not likely to have a material effect on the amounts distributable to any Member upon the dissolution of the Company.
Appears in 4 contracts
Samples: Limited Liability Company Agreement, Operating Agreement (Rex Energy Corp), Operating Agreement (Rex Energy Corp)
Compliance with Treasury Regulations. The foregoing provisions and the other provisions of this Agreement, as amended, Agreement relating to the maintenance of Capital Accounts are intended to comply with Treasury Regulation Regulations Section 1.704-1(b), and must shall be interpreted and applied in a manner consistent with those Treasury such Regulations. If In the Tax Matters Partner determines event the Management Board shall reasonably determine that it is prudent to modify the manner in which the Capital Accounts, or any debits or credits thereto, are computed in order to comply with those Treasury such Regulations, the Tax Matters Partner Management Board may make such modification, if provided, however, that it is shall not likely to have a material an adverse effect on the amounts distributable to any Member upon the dissolution of the CompanyMember.
Appears in 2 contracts
Samples: Operating Agreement (Gerova Financial Group LTD), Operating Agreement (FUND.COM Inc.)
Compliance with Treasury Regulations. The provisions of this Agreement, as amended, relating to the maintenance of Capital Accounts are intended to comply with Treasury Regulation Section 1.704-1(b), and must be interpreted and applied in a manner consistent with those Treasury Regulationssuch regulations. If In the Tax Matters Partner determines event the Managing Member shall determine that it is prudent to modify the manner in which the Capital Accounts, or any debits or credits thereto, are computed in order to comply with those Treasury Regulationssuch regulations, the Tax Matters Partner Managing Member may make such modification, if provided that it is not likely to have a material effect on the amounts distributable to any Member upon the dissolution of the Company.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Baseline Oil & Gas Corp.)