Contributed Assets. In accordance with Section 704(c) of the Code, income, gain, loss and deduction with respect to any property contributed to the Company with an adjusted basis for federal income tax purposes different from the initial Asset Value at which such property was accepted by the Company shall, solely for tax purposes, be allocated among the Members so as to take into account such difference in the manner required by Section 704(c) of the Code and the applicable Regulations.
Appears in 15 contracts
Samples: Limited Liability Company Agreement (U. S. Premium Beef, LLC), Limited Liability Company Agreement (New York REIT, Inc.), Limited Liability Company Agreement (Jefferies Financial Group Inc.)
Contributed Assets. In accordance with Section 704(c) of the Code, income, gain, loss and deduction with respect to any property contributed to the Company Partnership with an adjusted basis for U.S. federal income tax purposes different from the initial Asset Value at which such property was accepted by the Company Partnership shall, solely for tax purposes, be allocated among the Members Limited Partners so as to take into account such difference in the manner required by Section 704(c) of the Code and the applicable Regulations.
Appears in 3 contracts
Samples: Agreement of Exempted Limited Partnership (Taylor Morrison Home Corp), Agreement of Exempted Limited Partnership (Taylor Morrison Home Corp), Agreement of Exempted Limited Partnership
Contributed Assets. In accordance with Section 704(c) of the Code, income, gain, loss and deduction with respect to any property contributed (or deemed contributed for income tax purposes) to the Company with an adjusted basis for federal income tax purposes different from the initial Asset Value at which such property was accepted by the Company shall, solely for tax purposes, be allocated among the Members so as to take into account such difference in the manner required by Section 704(c) of the Code and the applicable Regulations.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Norcraft Companies, Inc.), Limited Liability Company Agreement (Norcraft Companies, Inc.)
Contributed Assets. In accordance with Section 704(c) of the Code, income, gain, loss and deduction with respect to any property contributed to the Company with an adjusted basis for federal income tax purposes different from the initial Asset Value at which such property was accepted by the Company shall, solely for tax purposes, be allocated among the Members so as to take into account such difference in the manner required by Section 704(c) of the Code and the applicable Regulationsregulations promulgated thereunder.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Marathon Patent Group, Inc.), Limited Liability Company Agreement (Inventergy Global, Inc.)
Contributed Assets. In accordance with Section 704(c) of the Code, income, gain, loss and deduction with respect to any property contributed to the Company with an adjusted basis for U.S. federal income tax purposes different from the initial Asset Value at which such property was accepted by the Company shallwill, solely for tax purposes, be allocated among the Members so as to take into account such difference in the manner required by Section 704(c) of the Code and the applicable Regulations.
Appears in 2 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement (Gryphon Gold Corp)
Contributed Assets. In accordance with Section 704(c) of the Code, income, gain, loss and deduction with respect to any property contributed to the Company with an adjusted basis for federal income tax purposes different from the initial Asset Value at which such property was accepted by the Company shall, solely for tax purposes, be allocated among the Members so as to take into account such difference in the manner required by Section 704(c) of the Code and the applicable Treasury Regulations.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (510152 N B LTD), Limited Liability Company Agreement (Jumpking Inc)
Contributed Assets. In accordance with Section 704(c) of the Code, income, gain, loss and deduction with respect to any property contributed to the Company with an adjusted basis for U.S. federal income tax purposes different from the initial Asset Value at which such property was accepted by the Company shall, solely for tax purposes, be allocated among the Members so as to take into account such difference in the manner required by Section 704(c) of the Code and the applicable RegulationsTreasury Regulations thereunder.
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