Revaluation of Partnership Property. The Capital Accounts of the Partners shall be adjusted to reflect a revaluation of the Partnership Property made by the General Partner pursuant to the definition of Gross Asset Value; provided that any adjustments hereunder shall be made in accordance with and to the extent provided in Treasury Regulations §1.704-1(b)(2)(iv)(f) and (g).
Revaluation of Partnership Property. The capital accounts of the Members shall be increased or decreased to reflect a revaluation of Company profit (including intangible assets such as goodwill) on the Company’s books in connection with such revaluation. Upon such revaluation: (1) the book value of Company property shall be adjusted based on the fair market value of Company property (taking Section 7701(g) of the Code into account) on the revaluation date; (2) the unrealized income, gain, loss, or deduction inherent in such Company property (that has not been reflected in the capital accounts previously) would be allocated among the Members as if there were a taxable disposition of such Company property for such fair market value on the revaluation date.
Revaluation of Partnership Property. The Capital Accounts of the Partners shall be increased or decreased to reflect a revaluation of Partnership Property (including intangible assets such as goodwill) on the Partnership's books in connection with a Revaluation Event. Upon such Revaluation: (1) the Book Value of Partnership Property shall be adjusted based on the fair market value of Partnership Property (taking Section 7701(g) of the Code into account) on the Revaluation Date; (2) the unrealized income, gain, loss, or deduction inherent in such Partnership Property (that has not been reflected in the Capital Accounts previously) would be allocated among the Partners as if there were a taxable disposition of such Partnership property for such fair market value on the Revaluation Date.
Revaluation of Partnership Property. The Capital Accounts of the Partners shall be adjusted to reflect a revaluation of Partnership property made by the Partnership pursuant to the definition of Gross Asset Value; provided that any adjustments hereunder shall be made in accordance with and to the extent provided in Treasury Regulations §1.704-1(b)(2)(iv)(e), (f), and (g). 78 The provisions in this Article 6 and the related definitions in Section 1.01 are for a Partnership using targeted capital accounts. Note that, as of the date of the Model, the IRS has not issued a revenue ruling regarding targeted allocations. SBA does not support or endorse any specific allocation method, and encourages applicants to discuss these provisions with their accountants and attorneys. An applicant is free to use other accounting systems and related alternative provisions.
Revaluation of Partnership Property. If there shall occur (i) an acquisition of Shares from the Partnership for more than a de minimis Capital Contribution, or (ii) a distribution (other than a de minimis distribution) to a Partner in redemption of his Shares, then the Partnership shall revalue the assets of the Partnership at their then fair market value and adjust the Capital Accounts in the same manner as provided in Section 18.1 in the case of a property distribution. Pursuant to this Section 8.6, the Capital Accounts of the Partners are adjusted to the amounts set forth on ANNEX A as of the date hereof. If there is a reallocation pursuant to this Section 8.6, then Capital Accounts shall thereafter be adjusted for allocations of depreciation (cost recovery) and gain or loss in accordance with the provisions of Treas. Reg. Sections 1.704-1(b)(2)(iv)(f) and (g), and the Partners' distributive Shares of depreciation (cost recovery) and gain or loss shall thereafter be computed in accordance with the principles of IRC Section 704(c) and the regulations promulgated thereunder using the traditional method with curative allocations within the meaning of Treas. Reg. Section 1.704-3(c).
Revaluation of Partnership Property. Upon the mutual agreement of the Partners, the Capital Accounts of the Partners may be adjusted to reflect a revaluation of the property of the Partnership (including intangible assets such as goodwill) to its fair market value in accordance with Treasury Regulations Section 1.704-1(b)(2)(iv)(f), at the following times: (a) in connection with the acquisition of an interest in the Partnership by a new or existing Partner for more than a de minimis capital contribution; (b) in connection with a distribution of money or other property (other than a de minimis amount) by the Partnership to a retiring or continuing Partner as consideration for an interest in the Partnership; or (c) in connection with the liquidation of the Partnership within the meaning of Treasury Regulations Section 1.704-1(b)(2)(ii)(g). In the event of any revaluation of the property of the Partnership hereunder, the Capital Accounts of the Partners shall be adjusted, including adjustments for depreciation, to the extent provided in Treasury Regulations Section 1.704-1(b)(2)(iv)(f) and (g).
Revaluation of Partnership Property. Upon (a) the admission of any Partner to the Partnership, (b) the liquidation of a Partner's interest in the Partnership, (c) the making of any additional capital contributions or partial withdrawals by a Partner which changes the Partner's relative percentage interest in the Partnership (other than a de minimus amount) as determined by reference to the relative balances in the Partner's Capital Accounts, or (d) immediately before liquidation of the Partnership, all the property of the Partnership shall be revalued at its fair market value as determined by the General Partners, and the Partners' Capital Accounts shall be adjusted to reflect the manner in which the unrealized income, gain, loss or deduction inherent in such property (that has not been reflected in adjustments to the Partners' Capital Accounts previously) would be allocated among the Partners if the property were sold at its fair market value on the valuation date.
Revaluation of Partnership Property. (a) Upon the occurrence of a Revaluation Event, the General Partner, in its sole discretion, may revalue all Partnership property (whether tangible or intangible) for Book purposes to reflect the Adjusted Fair Market Value of Partnership property immediately prior to the Revaluation Event. In the event that Partnership property is so revalued, the Capital Accounts of the Partners shall be adjusted in accordance with Treas. Reg. Section 1.704-1(b)(2)(iv)(f).
Revaluation of Partnership Property. Upon the occurrence of (i) a contribution of money or property to the Partnership (after the Closing Date) by a new or existing Partner as consideration for an interest in the Partnership, (ii) a distribution of money or property by the Partnership to a retiring or continuing Partner as consideration for an interest in the Partnership, or (iii) the liquidation of the Partnership, the respective Capital Accounts of all Partners shall be adjusted to reflect a revaluation of Partnership property on the books of the Partnership in the following manner:
