Section 704(c) Allocations. In the event any property of the Company is credited to the Capital Account of a Member at a value other than its tax basis (whether as a result of a contribution of such property or a revaluation of such property pursuant to subparagraph (b) of the definition of “Gross Asset Value”), then allocations of taxable income, gain, loss and deductions with respect to such property shall be made in accordance with the “traditional” allocation method described in Regulation § 1.704-3(b).
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Vantiv, Inc.), Limited Liability Company Agreement (Vantiv, Inc.), Limited Liability Company Agreement (Fifth Third Bancorp)
Section 704(c) Allocations. In the event that any property of the Company is credited to the Capital Account of a Member at a value other than its tax basis (whether as a result of a contribution of such property or a revaluation of such property pursuant to subparagraph clause (b) of the definition of “Gross Asset Value”), then allocations of taxable income, gain, loss and deductions with respect to such property shall be made in accordance with the “traditional” allocation using any method described provided for in Regulation § Section 1.704-3(b)3.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (J. Alexander's Holdings, Inc.), Limited Liability Company Agreement (J. Alexander's Holdings, Inc.), Limited Liability Company Agreement (J. Alexander's Holdings, Inc.)
Section 704(c) Allocations. In the event that any property of the Company is credited to the Capital Account of a Member at a value other than its tax basis (whether as a result of a contribution of such property or a revaluation of such property pursuant to subparagraph clause (b) of the definition of “Gross Asset Value”), then allocations of taxable income, gain, loss and deductions with respect to such property shall be made in accordance with using the “traditionaltraditional method” allocation method described provided for in Regulation § Section 1.704-3(b).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Black Knight Financial Services, Inc.), Limited Liability Company Agreement (Black Knight Financial Services, Inc.)
Section 704(c) Allocations. In the event that any property of the Company is credited to the Capital Account of a Member at a value other than its tax basis (whether as a result of a contribution of such property or a revaluation of such property pursuant to subparagraph clause (b) of the definition of “Gross Asset Value”), then allocations of taxable income, gain, loss and deductions with respect to such property shall be made using the traditional method provided for in accordance with the “traditional” allocation method described in Regulation § Regulations Section 1.704-3(b).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Black Knight, Inc.), Limited Liability Company Agreement (Cannae Holdings, Inc.)
Section 704(c) Allocations. In the event that any property of the Company is credited to the Capital Account of a Member at a value other than its tax basis (whether as a result of a contribution of such property or a revaluation of such property pursuant to subparagraph clause (b) of the definition of “Gross Asset Value”), then allocations of taxable income, gain, loss and deductions with respect to such property shall be made in accordance with the “traditional” allocation using any method described provided for in Regulation § Section 1.704-3(b).
Appears in 1 contract
Samples: Limited Liability Company Agreement (J. Alexander's Holdings, Inc.)
Section 704(c) Allocations. In the event that any property of the Company is credited to the Capital Account of a Member at a value other than its tax basis (whether as a result of a contribution of such property or a revaluation of such property pursuant to subparagraph clause (b) of the definition of “Gross Asset Value”), then allocations of taxable income, gain, loss and deductions with respect to such property shall be made in accordance with using any reasonable method as permitted by the “traditional” allocation method described in Regulation § 1.704-3(b)Code and the Regulations.
Appears in 1 contract
Section 704(c) Allocations. In the event that any property of the Company is credited to the Capital Account of a Member at a value other than its tax basis (whether as a result of a contribution of such property or a revaluation of such property pursuant to subparagraph clause (b) of the definition of “Gross Asset Value”), then allocations of taxable income, gain, loss and deductions with respect to such property shall be made in accordance using any method or methods selected by the Board of Managers that complies with Section 704(b) and Section 704(c) of the Code and the Regulations promulgated thereunder (“traditional” allocation method described in Regulation § 1.704-3(bSection 704(c) Allocations”).
Appears in 1 contract
Section 704(c) Allocations. In the event any property of the Company is credited to the Capital Account of a Member at a value other than its tax basis (whether as a result of a contribution of such property or a revaluation of such property pursuant to subparagraph (b) of the definition of “Gross Asset Value”), then allocations of taxable income, gain, loss and deductions with respect to such property shall be made in accordance with the “traditional” allocation method described in Regulation § Section 1.704-3(b).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Total System Services Inc)