Integration With Section 754 Election. All items of income, gain, loss, deduction and credits recognized by the Company for federal income tax purposes and allocated to the Members in accordance with the provisions hereof and all basis allocations to the Members shall be determined without regard to any election under section 754 of the Code that may be made by the Company; provided, however, such allocations, once made, shall be adjusted as necessary or appropriate to take into account the adjustments permitted by sections 734 and 743 of the Code.
Appears in 8 contracts
Samples: Limited Liability Company Agreement (Cadiz Inc), Limited Liability Company Agreement (Contango ORE, Inc.), Operating Agreement (Gold Torrent Canada Inc)
Integration With Section 754 Election. All items of income, gain, loss, deduction and credits credit recognized by the Company for federal income tax purposes and allocated to the Members in accordance with the provisions hereof and all basis allocations to the Members shall be determined without regard to any election under section 754 of the Code that may be made by the Company; provided, however, such allocations, once made, shall be adjusted as necessary or appropriate to take into account the adjustments permitted by sections 734 and 743 of the Code.
Appears in 3 contracts
Samples: Operating Agreement (Qwest Communications International Inc), Operating Agreement (Qwest Communications International Inc), Operating Agreement (Qwest Communications International Inc)
Integration With Section 754 Election. All items of income, gain, loss, deduction and credits recognized by the Company for federal income tax purposes and allocated to the Members in accordance with the provisions hereof and all basis allocations to the Members shall be determined without regard to any election under section Section 754 of the Code that may be made (or not made) by the CompanyCompany (at the election of Board in its sole and absolute discretion); provided, however, such allocations, once made, shall be adjusted as necessary or appropriate to take into account the adjustments permitted by sections Sections 734 and 743 of the Code.
Appears in 1 contract
Samples: Limited Liability Company Agreement
Integration With Section 754 Election. All items of income, gain, loss, deduction and credits recognized by the Company for federal income tax purposes and allocated to the Members in accordance with the provisions hereof and all basis allocations to the Members shall be determined without regard to any election under section Section 754 of the Code that may be made by the Company; provided, however, such allocations, once made, shall be adjusted as necessary or appropriate to take into account the adjustments permitted by sections Sections 734 and 743 of the Code.
Appears in 1 contract
Samples: Limited Liability Company Agreement
Integration With Section 754 Election. All items of income, gain, loss, deduction deduction, credit and credits basis allocations recognized by the Company for federal income tax purposes and allocated to the Members in accordance with the provisions hereof and all basis allocations to the Members shall will be determined without regard to any election under section Section 754 of the Code that may be made by the Company; provided, however, such allocations, once made, shall will be adjusted as necessary or appropriate to take into account the adjustments permitted by sections Sections 734 and 743 of the Code.
Appears in 1 contract
Samples: Operating Agreement
Integration With Section 754 Election. All items of income, gain, loss, deduction deduction, credit and credits basis allocations recognized by the Company for federal income tax purposes and allocated to the Members in accordance with the provisions hereof and all basis allocations to the Members of this Agreement shall be determined without regard to any election under section Section 754 of the Code that may be made by the Company; provided, however, such allocations, once made, shall be adjusted as necessary or appropriate to take into account the adjustments permitted by sections Sections 734 and 743 of the Code.
Appears in 1 contract
Samples: Operating Agreement
Integration With Section 754 Election. All items of income, gain, loss, deduction and credits recognized by the Company for federal income tax purposes and allocated to the Members in accordance with the provisions hereof and all basis allocations to the Members shall be determined without regard to any election under section 754 of the Code that #325596.v2 65 may be made by the Company; provided, however, such allocations, once made, shall be adjusted as necessary or appropriate to take into account the adjustments permitted by sections 734 and 743 of the Code.
Appears in 1 contract