Contributed Property. In accordance with IRC Section 704(c) and the Regulations, income, gain, loss, and 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 income tax purposes and its initial Gross Asset Value (computed in accordance with subparagraph 1.2.2.1 of this Exhibit "A").
Appears in 4 contracts
Samples: Operating Agreement (Salem Communications Corp /De/), Operating Agreement (Salem Communications Corp /De/), Operating Agreement (Salem Communications Corp /De/)
Contributed Property. In accordance with the rules of IRC Section § 704(c) and the RegulationsTreasury Regulations promulgated thereunder, items of income, gain, loss, and 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 income tax purposes and its initial Gross Asset Value (computed in accordance with subparagraph 1.2.2.1 fair market value at the time of this Exhibit "A")contribution.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (TCH Coal Co), Operating Agreement (Sunwin International Neutraceuticals, Inc.)
Contributed Property. In accordance with IRC Code Section 704(c) and the Regulations), income, gain, loss, loss and deduction with respect to any property contributed to the capital of the Company shall, solely for tax purposes, shall be allocated among the Members Members, solely for federal income tax purposes, so as to take account of any variation between the adjusted basis of such the property to the Company for federal income tax purposes and its the initial Gross Asset Value (computed of the property as of the date of the Capital Contribution of the property to the Company in accordance a manner consistent with subparagraph 1.2.2.1 of this Exhibit "A"Code Section 704(c) and Regulations Section 1.704-3(c).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Global Eagle Entertainment Inc.), Limited Liability Company Agreement (Global Eagle Entertainment Inc.)
Contributed Property. In accordance with IRC Section (S) 704(c) of the -------------------- Code and the RegulationsRegulations thereunder, income, gain, loss, and 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 income tax purposes and its initial Gross Asset Value (computed in accordance with subparagraph 1.2.2.1 of this Exhibit "A")Book Value.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Pacific Aerospace & Electronics Inc), Limited Liability Company Agreement (Pacific Aerospace & Electronics Inc)
Contributed Property. In accordance with the rules of IRC Section (S) 704(c) -------------------- and the RegulationsTreasury Regulations promulgated thereunder, items of income, gain, loss, and 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 income tax purposes and its initial Gross Asset Value (computed in accordance with subparagraph 1.2.2.1 fair market value at the time of this Exhibit "A")contribution.
Appears in 1 contract
Samples: Operating Agreement (Princess Beverly Coal Holding Co Inc)
