Revaluation. Pursuant to, and in accordance with, Section 1.704-1 of the Treasury Regulations, for U.S. federal income tax purposes (and any corresponding U.S. state or local tax purposes), the LLC shall revalue its property to fair market value as of the time of the Business Combination.
Appears in 4 contracts
Samples: Tax Receivable Agreement (QualTek Services Inc.), Tax Receivable Agreement (Sky Harbour Group Corp), Tax Receivable Agreement (Roth CH Acquisition III Co)
Revaluation. Pursuant to, and in accordance with, Section 1.704-1 of the Treasury Regulations, for U.S. federal income tax purposes (and any corresponding U.S. state or local tax purposes), the LLC Company shall revalue its property assets to fair market value as of the time of the Business Combinationclosing of the transactions contemplated by the Equity Purchase Agreement.
Appears in 2 contracts
Samples: Tax Receivable Agreement (Flyexclusive Inc.), Operating Agreement (EG Acquisition Corp.)
Revaluation. Pursuant to, and in accordance with, Section 1.704-1 of the Treasury Regulations, for U.S. federal income tax purposes (and any corresponding U.S. state or local tax purposes), the LLC shall revalue its property to fair market value as of the time of the Business Combination. The Parties hereto acknowledge and agree that such revaluation may result in subsequent Section 704(c) Items.
Appears in 2 contracts
Samples: Tax Receivable Agreement (Vivid Seats Inc.), Limited Liability Company Agreement (Horizon Acquisition Corp)
