Contributed or Revalued Property. Each Member’s allocable share of the taxable income or loss of the Company, depreciation, depletion, amortization and gain or loss with respect to any contributed property, or with respect to revalued property where the Company’s property is revalued pursuant to Paragraph (b)(2)(iv)(f) of Section 1.704-1 of the Treasury Regulations, shall be determined in the manner (and as to revaluations, in the same manner as) provided in Section 704(c) of the Code. The allocation shall take into account, to the full extent required or permitted by the Code, the difference between the adjusted basis of the property to the Member contributing it and the fair market value of the property determined by the Manager at the time of its contribution or revaluation, as the case may be. The Company shall apply Section 704(c)(1)(A) by using the “traditional method” as set forth in Section 1.704-3(b) of the Treasury Regulations.
Appears in 3 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement (Kennedy-Wilson Properties (IL)), Limited Liability Company Agreement (Kennedy-Wilson Properties (IL))
Contributed or Revalued Property. Each Member’s Economic Interest Holder's allocable share of the taxable income or loss of the Company, depreciation, depletion, amortization and gain or loss with respect to any contributed property, or with respect to revalued property where the Company’s 's property is revalued pursuant to Paragraph (b)(2)(iv)(f) of Section 1.704-1 of the Treasury Regulations, shall be determined in the manner (and as to revaluations, in the same manner as) provided in Section 704(c) of the Code. The allocation shall take into account, to the full extent required or permitted by the Code, the difference between the adjusted basis of the property to the Member Economic Interest Holder contributing it and the fair market value of the property determined by the Manager Managers at the time of its contribution or revaluation, as the case may be. The Company shall apply Section 704(c)(1)(A) by using the “"traditional method” " as set forth in Section 1.704-3(b) of the Treasury Regulations.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Internetstudios Com Inc), Limited Liability Company Agreement (Internetstudios Com Inc)
Contributed or Revalued Property. Each Member’s allocable share of the taxable income or loss of the Company, depreciation, depletion, amortization and gain or loss with respect to any contributed property, or with respect to revalued property where the Company’s property is revalued pursuant to Paragraph (b)(2)(iv)(f) of Section 1.704-1 of the Treasury Regulations, shall be determined in the manner (and as to revaluations, in the same manner as) provided in Section 704(c) of the Code. The allocation shall take into account, to the full extent required or permitted by the Code, the difference between the adjusted basis of the property to the Member contributing it and the fair market value Fair Market Value of the property determined by the Manager Managing Member at the time of its contribution or revaluation, as the case may be. The Company shall apply Section 704(c)(1)(A) by using the “traditional method” as set forth in Section 1.704-3(b) of the Treasury Regulations.
Appears in 1 contract
Contributed or Revalued Property. Each Member’s allocable share of the Company taxable income or loss of the Companyloss, or depreciation, depletion, amortization amortization, and gain or loss with respect to any contributed property, or with respect to revalued Company property where the Company’s property that is revalued pursuant to Paragraph (b)(2)(iv)(f) of Section Treasury Regulations § 1.704-1 of the Treasury Regulations1(b)(2)(iv)(f) and (g) or Section 10.11, shall be determined in the manner (and as to revaluations, in the same manner as) provided in Section 704(c) of the Code. The allocation shall take into account, to the full extent required or permitted by the Code, the difference between the adjusted basis of the property to the Member contributing (or deemed to be contributing) it and the fair market value Fair Market Value of the property determined by the Manager at the time of its contribution or revaluation, as the case may be, as determined by the Board. The Company shall apply Section 704(c)(1)(A) by using the “traditional method” as set forth in Section Treasury Regulations § 1.704-3(b) of the Treasury Regulations).
Appears in 1 contract
Contributed or Revalued Property. Each Member’s Economic Interest Holder's allocable share of the taxable income or loss of the Company, depreciation, depletion, amortization and gain or loss with respect to any contributed property, or with respect to revalued property where the Company’s 's property is revalued pursuant to Paragraph (b)(2)(iv)(f) of Section 1.704-1 of the Treasury Regulations, shall be determined in the manner (and as to revaluations, in the same manner as) provided in Section 704(c) of the Code. The allocation shall take into account, to the full extent required or permitted by the Code, the difference between the adjusted basis of the property to the Member Economic Interest Holder contributing it and the fair market value of the property determined by the Manager at the time of its contribution or revaluation, as the case may be. The Company shall apply Section 704(c)(1)(A) by using the “"traditional method” " as set forth in Section 1.704-3(b) of the Treasury Regulations.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Internetstudios Com Inc)
Contributed or Revalued Property. Each Member’s allocable share of the taxable income or loss of the Company, depreciation, depletion, amortization and gain or loss with respect to any contributed property, or with respect to revalued Company property where the Company’s property that is revalued pursuant to Paragraph (b)(2)(iv)(f) of Section Treasury Regulations § 1.704-1 of the Treasury Regulations1(b)(2)(iv)(f) or Section 1.8, shall be determined in the manner (and as to revaluations, in the same manner as) provided in Section 704(c) of the Code. The allocation shall take into account, to the full extent required or permitted by the Code, the difference between the adjusted basis of the property to the Member contributing (or deemed to be contributing) it and the fair market value Fair Market Value of the property determined by the Manager at the time of its contribution or revaluation, as the case may be, determined by the Managing Member. The Company shall apply Section 704(c)(1)(A) by using the “traditional method” as set forth in Section Treasury Regulations § 1.704-3(b) of the Treasury Regulations).
Appears in 1 contract
Samples: Operating Agreement