Special Rules Relating to Contributed Property Sample Clauses
The "Special Rules Relating to Contributed Property" clause defines how property contributed by partners to a partnership is treated for accounting and tax purposes. Typically, this clause outlines procedures for tracking the original value of contributed assets, allocating income, gain, or loss associated with those assets, and addressing any differences between book and tax values. For example, it may specify how appreciation or depreciation in the value of contributed property is allocated among partners. The core function of this clause is to ensure fair and accurate allocation of tax consequences and economic benefits related to contributed property, thereby preventing inequities among partners and complying with tax regulations.
Special Rules Relating to Contributed Property. Solely for tax ---------------------------------------------- purposes (and not for Capital Account purposes), in the case of any property (other than cash) included in a Capital Contribution, items of income, gain, loss, deduction, and credit attributable to such contributed property shall be allocated as follows:
(1) first, among the Members in a manner that takes into account ----- the variation between the fair market value of such property and its Adjusted Basis at the time of contribution (in accordance with Section 704(c) of the Code and applicable Regulations), and
(2) thereafter, in accordance with Section 7.1 and the other ---------- provisions of this Article.
Special Rules Relating to Contributed Property. Solely for tax ---------------------------------------------- purposes (and not for Capital Account purposes), in the case of any property (other than cash) included in a Capital Contribution, or that is held by the Company on the date any adjustment of Percentage Interest is made pursuant to Section 8.5, items of income, gain, loss, deduction, and credit attributable to such contributed property shall be allocated as follows:
(1) first, among the Members in a manner that takes into account the ----- variation between the fair market value of such property and its Adjusted Basis at the time of contribution or adjustment of Percentage Interests (in accordance with Section 704(c) of the Code and applicable Treasury Regulations), and
(2) thereafter, in accordance with Section 8.1 and the other ---------- provisions of this Article.