Election; Allocations Between Transferor and Transferee. Upon the Transfer of the Interest of any Member or the distribution of any property of the Company to a Member, the Company may file, with the approval of the Management Committee, in its sole and absolute discretion, an election in accordance with applicable Treasury Regulations, to cause the basis of the Company property to be adjusted for federal income tax purposes as provided by Sections 734 and 743 of the Code.
Appears in 15 contracts
Samples: Operating Agreement, Limited Liability Company Agreement, Operating Agreement
Election; Allocations Between Transferor and Transferee. Upon the Transfer transfer of the Membership Interest of in the Company by any Member or the distribution of any property of the Company to a Member, the Company Manager may file, with the approval of the Management Committee, in its sole and absolute discretion, file an election in accordance with applicable Treasury Regulations, to cause the basis of the Company property to be adjusted for federal income tax purposes as provided by Sections 734 and 743 of the Code.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Limoneira CO), Contribution Agreement (Limoneira CO)
