Section 754 Election. In the event of a distribution of the Fund's property to a Member or an assignment or other transfer (including by reason of death) of Units of a Member in the Fund, at the request of a Member, the Board, in its sole and absolute discretion, may cause the Fund to elect, pursuant to Section 754 of the Code, or the corresponding provision of subsequent law, to adjust the basis of the Fund's property as provided by Sections 734 and 743 of the Code.
Appears in 16 contracts
Samples: Limited Liability Company Agreement (CSFB Alternative Capital Long/Short Equity Institutional Fund, LLC), Limited Liability Company Agreement (CSFB Alternative Capital Tactical Trading Institutional Fund, LLC), Limited Liability Company Agreement (CSFB Alternative Capital Relative Value Institutional Fund, LLC)
Section 754 Election. In the event of a distribution of the Fund's Fund property to a Member or an assignment or other transfer (including by reason of death) of Units all or part of the interest of a Member in the Fund, at the request of a Member, the BoardBoard of Managers, in its sole and absolute discretion, may cause the Fund to elect, pursuant to Section 754 of the Code, or the corresponding provision of subsequent law, to adjust the basis of the Fund's Fund property as provided by Sections 734 and 743 of the Code.
Appears in 7 contracts
Samples: Limited Liability Company Agreement (Aetos Capital Opportunities Fund, LLC), Limited Liability Company Agreement (Oppenheimer Tremont Market Neutral Fund LLC), Limited Liability Company Agreement (Oppenheimer Tremont Opportunity Fund LLC)
Section 754 Election. In the event of a distribution of the Fund's Fund property to a Member or an assignment or other transfer (including by reason of death) of Units all or part of the interest of a Member in the Fund, at the request of a Member, the BoardBoard of Directors, in its sole and absolute discretion, may cause the Fund to elect, pursuant to Section 754 of the Code, or the corresponding provision of subsequent law, to adjust the basis of the Fund's Fund property as provided by Sections 734 and 743 of the Code.
Appears in 4 contracts
Samples: Operating Agreement (Asa Debt Arbitrage Fund LLC), Operating Agreement (Asa Hedged Equity Fund LLC), Limited Liability Company Operating Agreement (Asa Market Neutral Equity Fund LLC)
Section 754 Election. In the event of a distribution of the Fund's ’s property to a Member or an assignment or other transfer Transfer (including by reason of death) of Units of a Member in the Fund, at the request of a Member, the Board, in its sole and absolute discretion, may cause the Fund to elect, pursuant to Section 754 of the Code, or the corresponding provision of subsequent law, to adjust the basis of the Fund's ’s property as provided by Sections 734 and 743 of the Code.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Wells Fargo Multi-Strategy 100 Tei Fund A, LLC), Limited Liability Company Agreement (Wells Fargo Multi-Strategy 100 Tei Fund A, LLC), Limited Liability Company Agreement (Wells Fargo Multi-Strategy 100 Master Fund I, LLC)
Section 754 Election. In the event of a distribution of the Fund's Fund property to a Member or an assignment or other transfer (including by reason of death) of Units all or part of the interest of a Member in the Fund, at the request Board of a Member, the BoardDirectors, in its sole and absolute discretion, may cause the Fund to elect, pursuant to Section 754 of the Code, or the corresponding provision of subsequent law, to adjust the basis of the Fund's property as provided by Sections 734 and 743 of the Code.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (SCS Hedged Opportunities Master Fund, LLC), Limited Liability Company Agreement (SCS Hedged Opportunities Master Fund, LLC)
Section 754 Election. In the event of a distribution of the Fund's Fund property to a Member Holder or an assignment or other transfer (including by reason of death) of Units all or part of the interest of a Member Holder in the Fund, at the request of a MemberHolder, the BoardBoard of Trustees, in its sole and absolute discretion, may cause the Fund to elect, pursuant to Section 754 of the Code, or the corresponding provision of subsequent law, to adjust the basis of the Fund's Fund property as provided by Sections 734 and 743 of the Code.
Appears in 2 contracts
Samples: Trust Agreement (Wilmington Low Volatility Fund of Funds), Agreement and Declaration of Trust (Wilmington Low Volatility Fund of Funds)
Section 754 Election. In the event of a distribution of the Fund's property to a Member or an assignment or other transfer (including by reason of death) of Units of a Member in the Fund, at the request of a Member, the Board, in its sole and absolute discretion, may cause the Fund to elect, pursuant to Section 754 of the Code, or the corresponding provision of subsequent law, to adjust the basis of the Fund's property as provided by Sections 734 and 743 of the Code.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Man Ip 220 LLC)
Section 754 Election. In the event of a distribution of the Fund's ’s property to a Member or an assignment or other transfer Transfer (including by reason of death) of Units the Interest of a Member in the Fund, at the request of a Member, the Board, in its sole and absolute discretion, may cause the Fund to elect, pursuant to Section 754 of the Code, or the corresponding provision of subsequent law, to adjust the basis of the Fund's ’s property as provided by Sections 734 and 743 of the Code.
Appears in 1 contract
Samples: Limited Liability Company Agreement (ASGI Aurora Opportunities Fund, LLC)
Section 754 Election. In the event of a distribution of the Fund's Fund property to a Member or an assignment or other transfer (including by reason of death) of Units all or part of the interest of a Member in the Fund, at the request Board of a Member, the BoardDirectors, in its sole and absolute discretion, may cause the Fund to elect, pursuant to Section 754 of the Code, or the corresponding provision of subsequent law, to adjust the basis of the Fund's ’s property as provided by Sections 734 and 743 of the Code.
Appears in 1 contract
Samples: Limited Liability Company Agreement (SCS Hedged Opportunities Fund, LLC)
