Section 704(c) Allocations. In the event that the Book Value of an item of Company property differs from its Tax Basis, allocations of depreciation, depletion, amortization, gain, and loss with respect to such property will be made for federal income tax purposes in a manner that takes account of the variation between the Tax Basis and Book Value of such property in accordance with Section 704(c) (1) (A) of the Code and Treas. Reg. Section 1.704-1(b) (4) (i). The Managing Member shall have discretion to determine the appropriate method for making such allocations
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Rouse Properties, Inc.), Limited Liability Company Agreement (Rouse Properties, Inc.), Limited Liability Company Agreement (Rouse Properties, Inc.)
Section 704(c) Allocations. In the event that If the Book Value of an item of Company property differs from its Tax Basis, allocations of depreciation, depletion, amortization, gain, gain and loss with respect to such property will be made for U.S. federal income tax purposes in a manner that takes account of the variation between the Tax Basis and Book Value of such property in accordance with Section 704(c) (1) (A704(c)(1)(A) of the Code and Treas. Reg. Section 1.704§ l.704-1(b) (4) (i1(b)(4)(i). The Managing Member shall have discretion to determine the appropriate Executive Committee may select any reasonable method or methods for making such allocations, unless otherwise required by Section 6.10(b) of the Purchase Agreement.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (NorthStar Asset Management Group Inc.), Unit Purchase Agreement (NorthStar Asset Management Group Inc.)