Common use of Contributed Property and Book-Ups Clause in Contracts

Contributed Property and Book-Ups. In accordance with Code Section 704(c) and the Regulations thereunder, as well as Treas. Reg. Section 1.704-1(b)(2)(iv)(d)(3), income, gain, loss, and deduction with respect to any property contributed (or deemed contributed) to the Partnership shall, solely for tax purposes, be allocated among the Interest Holders so as to take account of any variation between the adjusted basis of the property to the Partnership for federal income tax purposes and its fair market value at the date of contribution (or deemed contribution). If the adjusted book value of any Partnership asset is adjusted as provided herein, subsequent allocations of income, gain, loss, and deduction with respect to the asset shall take account of any variation between the adjusted basis of the asset for federal income tax purposes and its adjusted book value in the manner required under Code Section 704(c) and the Regulations thereunder.

Appears in 3 contracts

Samples: Limited Partnership Agreement (Corporate Property Associates 15 Inc), Limited Partnership Agreement (Corporate Property Associates 15 Inc), Limited Partnership Agreement (Corporate Property Associates 15 Inc)

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Contributed Property and Book-Ups. In accordance with Code Section 704(c) and the Regulations regulations thereunder, as well as Treas. Reg. Treasury Regulations Section 1.704-1(b)(2)(iv)(d)(3l(b)(2)(iv)(d)(3), income, gain, loss, and deduction with respect to any property contributed (or deemed contributed) to the Partnership Company shall, solely for tax purposes, be allocated among the Interest Holders so as to take account of any variation between the adjusted basis of the property to the Partnership Company for federal income federal-income-tax purposes and its fair market value at on the date of contribution (or deemed contribution). If the adjusted book value of any Partnership Company asset is adjusted as provided herein, subsequent allocations of income, gain, loss, and deduction with respect to the asset shall take account of any variation between the adjusted basis of the asset for federal income tax purposes and its adjusted book value in the manner required under Code Section 704(c) and the Regulations regulations thereunder.

Appears in 1 contract

Samples: Operating Agreement (Banyan Corp /Or/)

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Contributed Property and Book-Ups. In accordance with Code Section 704(c) and the Regulations thereunder, as well as Treas. Reg. Section 1.704-1(b)(2)(iv)(d)(3§ 1.704‑1(b)(2)(iv)(d)(3), income, gain, loss, and deduction with respect to any property contributed (or deemed contributed) to the Partnership Company shall, solely for tax purposes, be allocated among the Interest Holders so as to take account of any variation between the adjusted basis of the property to the Partnership Company for federal income tax purposes and its fair market value at the date of contribution (or deemed contribution). If the adjusted book value of any Partnership Company asset is adjusted as provided herein, subsequent allocations of income, gain, loss, and deduction with respect to the asset shall take account of any variation between the adjusted basis of the asset for federal income tax purposes and its adjusted book value in the manner required under Code Section 704(c) and the Regulations thereunder.

Appears in 1 contract

Samples: Limited Liability Company Operating Agreement (Corporate Property Associates 18 Global Inc)

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