Special Basis Adjustments. In connection with any assignment or transfer of a Company interest permitted by the terms of this Agreement, the Managing Member may cause the Company, on behalf of the Members and at the time and in the manner provided in Code Regulations Section 1.754-1(b), to make an election to adjust the basis of the Company’s property in the manner provided in Sections 734(b) and 743(b) of the Code.
Appears in 28 contracts
Samples: Limited Liability Agreement, Limited Liability Company Agreement (Blackstone Group L.P.), Limited Liability Company Agreement (Blackstone Group L.P.)
Special Basis Adjustments. In connection with a distribution of Company property to a Member or any assignment or transfer of a Company interest permitted by the terms of this Agreement, the Managing Member may cause the Company, on behalf of the Members and at the time and in the manner provided in Code Regulations Section 754 and Regulation Section 1.754-1(b), to make an election to adjust the basis of the Company’s property in the manner provided in Sections 734(b) and 743(b) of the Code.
Appears in 3 contracts
Samples: www.sec.gov, Blackstone Real Estate Special (Blackstone Group L.P.), Limited Liability Company Agreement (Blackstone Group L.P.)
Special Basis Adjustments. In connection with any assignment or transfer of a Company interest permitted by the terms of this Agreement, the Managing Member may cause the Company, on behalf of the Members and at the time and in the manner provided in Code Treasury Regulations Section 1.754-1(b), to make an election to adjust the basis of the Company’s property in the manner provided in Sections 734(b) and 743(b) of the Code.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Blackstone Group L.P.), Limited Liability Company Agreement (Blackstone Group L.P.), Limited Liability Company Agreement (Blackstone Group L.P.)
Special Basis Adjustments. In connection with a distribution of Company property to a Member or any assignment or transfer of a Company interest permitted by the terms of this Agreement, the Managing Member may cause the Company, on behalf of the Members and at the time and in the manner provided in Code Regulations Section 754 and Treasury Regulation Section 1.754-1(b), to make an election to adjust the basis of the Company’s property in the manner provided in Sections 734(b) and 743(b) of the Code.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Blackstone Group L.P.), Limited Liability Company Agreement (Blackstone Group L.P.), Limited Liability Company Agreement (Blackstone Group L.P.)
Special Basis Adjustments. In connection with any assignment or transfer of a Company interest permitted by the terms of this Agreement, the Managing Member may cause the Company, on behalf of the Members and at the time and in the manner provided in Code Treasury Regulations Section 1.754-1(b), to make an election to adjust the basis of the Company’s property in the manner provided in Sections 734(b) and 743(b) of the Code.. ARTICLE VII CAPITAL COMMITMENT INTERESTS; CAPITAL CONTRIBUTIONS; ALLOCATIONS; DISTRIBUTIONS
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Blackstone Group Inc), Limited Liability Company Agreement (Blackstone Group L.P.)
Special Basis Adjustments. In connection with any assignment or transfer of a Company interest permitted by the terms of this Agreement, the Managing Member may cause the Company, on behalf of the Members and at the time and in the manner provided in Code Regulations regulation Section 1.754-1(b), to make an election to adjust the basis of the Company’s property in the manner provided in Sections 734(b) and 743(b) of the Code.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Blackstone Group L.P.), Limited Liability Company Agreement (Blackstone Group L.P.)
Special Basis Adjustments. In connection with any assignment or transfer of a Company interest permitted by the terms of this Agreement, the Managing Member may cause the Company, on behalf of the Members and at the time and in the manner provided in Code Regulations Section 1.754-1(b), to make an election to adjust the basis of the Company’s property in the manner provided in Sections 734(b) and 743(b) of the Code.. 57
Appears in 1 contract
Samples: Limited Liability Company Agreement