Guaranteed Payments. To the extent any compensation paid to any Member by the Company, is determined by the Internal Revenue Service not to be a guaranteed payment under IRC Section 707(c) or is not paid to the Member other than in the Person's capacity as a partner (Member) within the meaning of IRC Section 707(a), the Member shall be specially allocated gross income of the Company in an amount equal to the amount of that compensation, and the Member's Capital Account shall be adjusted to reflect the payment of that compensation.
Appears in 4 contracts
Samples: Operating Agreement (New England Cape Gods, Inc.), Operating Agreement (Rock Fund VII-A, LLC), Operating Agreement (Rock Fund VII-A, LLC)
Guaranteed Payments. To the extent that any compensation paid to any a Member by the Company, Company is determined by the Internal Revenue Service not to be a guaranteed payment under IRC Section § 707(c) or is not paid to be a transaction between the Member other than in and the Person's capacity as a partner (Member) within the meaning of Company under IRC Section § 707(a), the Member shall will be specially allocated gross income of the Company in an amount equal to the amount of that compensation, compensation payment and the Member's ’s Capital Account shall will be adjusted to reflect treat the compensation payment of that compensationas a distribution.
Appears in 1 contract
Samples: Operating Agreement (Visual Management Systems Inc)
