Special Basis Adjustment. At the request of either the transferor or transferee in connection with a transfer of an Interest in the Company approved by the Members pursuant to Article 16 of this Agreement, the Managers shall cause the Company to make the election provided for in Code Section 754 and maintain a record of the adjustments to Basis of Property resulting from that election. Any such transferee shall pay all costs incurred by the Company in connection with such election and the maintenance of such records.
Special Basis Adjustment. At the request of either the transferor or transferee in connection with a transfer of an Interest in the Company approved by the Members pursuant to Article 13 of this Agreement, the Managers shall cause the Company to make the election provided for in Code Section 754 and maintain a record of the adjustments to Basis of Property resulting from that election. Any such transferee shall pay all costs incurred by the Company in connection with such election and the maintenance of such records.
Special Basis Adjustment. The Tax Matters Member shall, without any further consent of the Members being required (except as specifically required herein), have discretion to make an election for federal income tax purposes to adjust the basis of property pursuant to Sections 754, 734 (b) and 743 (b) of the Code, or comparable provisions of state, local or foreign law, in connection with Transfers of Units and Company Distributions.
Special Basis Adjustment. In connection with any Transfer of a Company interest, the Company shall, if the transferor or the transferee so requests and the Manager agrees, elect, at the time and in the manner provided in Regulations Section 1.754-1(b), to adjust the basis of the Company’s property in the manner provided in Section 743(b) of the Code, and such transferee shall pay all costs incurred by the Company in connection therewith, including, without limitation, reasonable attorneys’ and accountants’ fees.
Special Basis Adjustment. At the request of either the transferor or transferee in connection with a transfer of a Membership Interest in the Company, the Board will, at the request of any Member, cause the Company to make the election provided for in Code Section 754 and maintain a record of the adjustments to Basis of Property resulting from that election. Any such transferee shall pay all costs incurred by the Company in connection with such election and the maintenance of such records.
Special Basis Adjustment. In connection with Distributions or any assignment or transfer of a Partnership Interest permitted by the terms of this Agreement, the General Partner in its discretion may cause the Partnership, at the written request of the transferor or the transferee with respect to a transfer of a Partnership Interest, on behalf of the Partnership and at the time and in the manner provided in the Regulations, to make an election to adjust the basis of Partnership Property in the manner provided in Sections 734(b), 743(b) and 754 of the Code. If such election is made with respect to a transfer of a Partnership Interest, the transferee shall pay all costs incurred by the Partnership in connection therewith, including without limitation, reasonable attorneys' and accountants' fees.
Special Basis Adjustment. The Tax Matters Member shall not, without the prior written consent of the other Members, such consent not to be unreasonably withheld, make an election for federal income tax purposes to adjust the basis of property pursuant to Sections 754, 734(b) and 743(b) of the Code, or comparable provisions of state, local or foreign law, in connection with Distributions.
Special Basis Adjustment. In connection with any Transfer of a Membership Interest (including any Class Interest) permitted by the terms of this Agreement, the Tax Matters Member may cause the Company, at the written request of the transferor, the transferee or the successor to such Membership Interest (and shall cause the Company, in the case of a Transfer to or from an affiliate of a Member) on behalf of the Company and at the time and in the manner provided in Treasury Regulation Section 1.754-1(b) (or any like statute or regulation then in effect), to make an election to adjust the basis of the Company's property in the manner provided in Code Sections 734(b) and 743(b) (or any like statute or regulation then in effect), and such transferee shall pay all costs incurred by the Company in connection therewith, including reasonable attorneys' and accountants' fees.
Special Basis Adjustment. In connection with any Transfer of a Partnership Interest permitted under Article 6, the Operating Committee shall cause the Partnership, at the written request of the transferor or the Transferee, but only upon the approval of the General Partners, on behalf of the Partnership and at the time and in the manner provided in Regulations Section 1.754-1(b), to make an election to adjust the basis of the Partnership's property in the manner provided in Sections 734(b) and 743(b) of the Code, and the Transferee shall pay all costs incurred by the Partnership in connection therewith, including reasonable attorneys' and accountants' fees.
