Common use of Distributions of Property Clause in Contracts

Distributions of Property. In the event that property is distributed by the Trust to a Shareholder, the following special rules shall apply: (i) the Capital Account of the Shareholder receiving the distribution first shall be adjusted to the extent required (as provided in Treas. Reg. ss. 1.704-l(b)(2)(iv)(e)) to reflect the manner in which the unrealized income, gain, loss and deduction inherent in such property (that has not already been reflected in such Shareholder's Capital Account) would be allocated to such Shareholder if there were a taxable disposition of such property for its fair market value on the date of distribution; and (ii) the Capital Account of the Shareholder who is receiving the distribution of property from the Trust shall be charged with the fair market value of the property at the time of distribution (net of liabilities secured by such property that such Shareholder is considered to assume or take subject to under Section 752 of the Code).

Distributions of Property. In the event that property is distributed by the Trust to a Shareholder, the following special rules shall apply: (i) the Capital Account of the Shareholder receiving the distribution first shall be adjusted to the extent required (as provided in Treas. Reg. ss. 1.704-l(b)(2)(iv)(e1(b)(2)(iv)(e)) to reflect the manner in which the unrealized income, gain, loss and deduction inherent in such property (that has not already been reflected in such Shareholder's Capital Account) would be allocated to such Shareholder if there were a taxable disposition of such property Shareholder for its fair market value on the date of distribution; and (ii) the Capital Account of the Shareholder who is receiving the distribution of property from the Trust shall be charged with the fair market value of the property at the time of distribution (net of liabilities secured by such property that such Shareholder is considered to assume or take subject to under Code Section 752 of the Code752).

Distributions of Property. In the event that property is distributed by the Trust to a Shareholder, the following special rules shall apply: (i) the Capital Account of the Shareholder receiving the distribution first shall be adjusted to the extent required (as provided in Treas. Reg. ss. § 1.704-l(b)(2)(iv)(e1(b)(2)(iv)(e)) to reflect the manner in which the unrealized income, gain, loss and deduction inherent in such property (that has not already been reflected in such Shareholder's ’s Capital Account) would be allocated to such Shareholder if there were a taxable disposition of such property Shareholder for its fair market value on the date of distribution; and (ii) the Capital Account of the Shareholder who is receiving the distribution of property from the Trust shall be charged with the fair market value of the property at the time of distribution (net of liabilities secured by such property that such Shareholder is considered to assume or take subject to under Code Section 752 of the Code752).

Distributions of Property. In the event that property is distributed by the Trust to a Shareholder, the following special rules shall apply: (i) the Capital Account of the Shareholder receiving the distribution first shall be adjusted to the extent required (as provided in Treas. Reg. ss. Section 1.704-l(b)(2)(iv)(e1(b)(2)(iv)(e)) to reflect the manner in which the unrealized income, gain, loss and deduction inherent in such property (that has not already been reflected in such Shareholder's Capital Account) would be allocated to such Shareholder if there were a taxable disposition of such property Shareholder for its fair market value on the date of distribution; and (ii) the Capital Account of the Shareholder who is receiving the distribution of property from the Trust shall be charged with the fair market value of the property at the time of distribution (net of liabilities secured by such property that such Shareholder is considered to assume or take subject to under Code Section 752 of the Code752).