Member Section 482 Adjustment. If the Internal Revenue Service or any applicable state or local taxing authority reallocates an item of income, deduction or loss to a Member or an Affiliate of such Member pursuant to Code Section 482 or any similar rule or principle of law (a “Member Section 482 Allocation”), and the Company has a corresponding “correlative item,” as determined under Regulations Section 1.482-1(g) (the “Company Correlative Item”), such Company Correlative Item shall be specially allocated to and reflected in the Capital Account of the Member that received (or whose Affiliate received) such Member Section 482 Allocation, and such Member shall be treated as making any corresponding deemed capital contribution or receiving any corresponding deemed distribution, with such deemed capital contribution or distribution, as the case may be, reflected in the Capital Account of such Member.
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Samples: Limited Liability Company Operating Agreement, Limited Liability Company (Advanced Micro Devices Inc), Limited Liability Company (Advanced Micro Devices Inc)
Member Section 482 Adjustment. If the Internal Revenue Service or any applicable state or local taxing authority reallocates an item of income, deduction or loss to a Member or an Affiliate of such Member pursuant to Code Section 482 or any similar rule or principle of law (a “"Member Section 482 Allocation”"), and the Company has a corresponding “"correlative item,” " as determined under Regulations Section 1.482-1(g) (the “"Company Correlative Item”"), such Company Correlative Item shall be specially allocated to and reflected in the Capital Account of the Member that received (or whose Affiliate received) such Member Section 482 Allocation, and such Member shall be treated as making any corresponding deemed capital contribution or receiving any corresponding deemed distribution, with such deemed capital contribution or distribution, as the case may be, reflected in the Capital Account of such Member.
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