Contributed Property. Income, gain, loss and deduction, as computed for the purpose of determining taxable income, with respect to any property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Members so as to take account of any variation between the adjusted basis of such property to the Company for Federal income tax purposes and its initial Gross Asset Value in accordance with Code Section 704(c) and the Regulations thereunder.
Appears in 4 contracts
Samples: Operating Agreement (MacKenzie Realty Capital, Inc.), Limited Liability Company Agreement (MacKenzie Realty Capital, Inc.), Operating Agreement (MacKenzie Realty Capital, Inc.)
Contributed Property. IncomeIn accordance with Code Section 704(c) and the Treasury Regulations thereunder, income, gain, loss and deduction, as computed for the purpose of determining taxable income, deduction with respect to any property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Members so as to take account of any variation between the adjusted basis of such property to the Company for Federal federal income tax purposes and its initial Gross Asset Value in accordance with Code Section 704(c) and the Regulations thereunderValue.
Appears in 3 contracts
Samples: Limited Liability Company Operating Agreement (Bequest Bonds I Inc), Operating Agreement (Bequest Bonds I Inc), Operating Agreement (Bequest Bonds I Inc)
Contributed Property. IncomeIn accordance with §704(c) of the Code and the Regulations thereunder, income, gain, loss loss, and deduction, as computed for the purpose of determining taxable income, deduction with respect to any property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Members so as to take account of any variation between the adjusted basis of such property to the Company for Federal federal income tax purposes and its initial Gross Asset Value in accordance with Code Section 704(c) and the Regulations thereunderBook Value.
Appears in 2 contracts
Samples: Operating Agreement (Hallmark Financial Services Inc), Operating Agreement (Hallmark Financial Services Inc)
Contributed Property. IncomeIn accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss and deduction, as computed for the purpose of determining taxable income, deduction with respect to any property contributed to the capital of the Company shallassets shall be, solely for tax purposes, be allocated among the Members so as to take account of any variation between the adjusted basis of such property asset to the Company for Federal federal income tax purposes and its initial Gross Asset Value in accordance with Code Section 704(c) and the Regulations thereunderValue.
Appears in 2 contracts
Samples: Operating Agreement (Xspand Products Lab, Inc.), Operating Agreement (Xspand Products Lab, Inc.)
Contributed Property. Income, gain, loss and deduction, as computed for the purpose of determining taxable income, deductions with respect to any property contributed to the capital of the Company shall, solely for federal income tax purposes, be allocated among the Members so as to take account of any variation between the adjusted basis of such property to the Company for Federal federal income tax purposes and its initial Gross Asset Value fair market value at time of contribution in accordance with Code Section 704(c) and the Treasury Regulations thereunder.
Appears in 1 contract
Samples: Operating Agreement
Contributed Property. Income, gain, Net income or net loss and deduction, as computed for the purpose of determining taxable income, with respect to any property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Members so as to take account of any variation between the adjusted basis of such property to the Company for Federal federal income tax purposes and its initial Gross Asset Value value at the time of the contribution of such property to the Company in accordance with Code Section 704(c) and the Regulations thereunder).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Commerce Street Pantheon Mortgage Asset Securitizations LLC)
Contributed Property. Income, gain, loss and -------------------- deduction, as computed for the purpose of determining taxable income, with respect to any property contributed to the capital of the Company Partnership shall, solely for tax purposes, be allocated among the Members Partners so as to take account of any variation between the adjusted basis of such property to the Company Partnership for Federal federal income tax purposes and its initial Gross Asset Value in accordance with Code Section 704(c) and the Regulations thereunder.
Appears in 1 contract
Samples: Limited Partnership Agreement (Styrochem International LTD)
Contributed Property. IncomeIn accordance with Code Section 704(c) and the Treasury Regulations thereunder, income, gain, loss and deduction, as computed for the purpose of determining taxable income, deduction with respect to any property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Members so as to take account of any variation between the adjusted basis of such property to the Company for Federal federal income tax purposes and its initial Gross Asset Value in accordance with Code Section 704(c) and fair market value at the Regulations thereundertime of its contribution to the Company.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Black Amber Florida, Inc.)