Income Taxes and Tax Capital Accounts. (a) Each item of income, gain, loss, deduction or credit shall be allocated in the same manner as such item is allocated pursuant to Section 4.2. (b) In the event of any variation between the adjusted tax basis and value of any Company property reflected in the Members’ capital accounts maintained for federal income tax purposes, such variation shall be taken into account in allocating taxable income or loss for income tax purposes in accordance with, and to the extent consistent with, the principles under Section 704(c) of the Code and applicable Treasury Regulations.
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Samples: Limited Liability Company Agreement, Limited Liability Company Agreement (Golub Capital BDC 3, Inc.), Limited Liability Company Agreement (Golub Capital Investment Corp)
Income Taxes and Tax Capital Accounts. (a) Each item of income, gain, loss, deduction or credit shall be allocated in the same manner as such item is allocated pursuant to Section 4.25.2.
(b) In the event of any variation between the adjusted tax basis and value of any Company property reflected in the Members’ capital accounts maintained for U.S. federal income tax purposes, such variation shall be taken into account in allocating taxable income or loss for income tax purposes in accordance with, and to the extent consistent with, the principles under Section 704(c) of the Code and applicable Treasury Regulations.
Appears in 1 contract
Samples: Limited Liability Company Agreement (SLR Investment Corp.)
Income Taxes and Tax Capital Accounts. (a) Each item of income, gain, loss, deduction or credit shall be allocated in the same manner as such item is allocated pursuant to Section 4.24.02.
(b) In the event of any variation between the adjusted tax basis and value of any Company property reflected in the Members’ capital accounts maintained for federal income tax purposes, such variation shall be taken into account in allocating taxable income or loss for income tax purposes in accordance with, and to the extent consistent with, the principles under Section 704(c) of the Code and applicable Treasury Regulations.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Owl Rock Capital Corp)