SPECIAL TAX ELECTIONS Sample Clauses

SPECIAL TAX ELECTIONS. With respect to Section 4.1, the Parties agree (if not applicable insert “N/A” or strike):
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SPECIAL TAX ELECTIONS. 9 9.3 CHANGE OF MAJORITY FOR OTHER TAX ELECTIONS .....................................................10 JOA - Exhibit "F" ii
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SPECIAL TAX ELECTIONS. With respect to Section 4.1(d), the Parties agree (if not applicable insert “N/A” or strike): that the Partnership shall elect to account for dispositions of depreciable assets under the general asset method to the extent permitted by Code §168(i)(4); N/A that the Partnership shall elect under Code §754 to adjust the basis of Partnership property, with the adjustments provided in Code §734 for a distribution of property and in Code §743 for a transfer of a partnership interest. In case of distribution of property the TRP shall adjust all tax basis capital accounts. In the case of a transfer of a partnership interest the acquiring party(ies) shall establish and maintain its (their) tax basis capital account(s); √ that the Partnership shall elect under Code §6231 to be subject to the TEFRA rules. N/A § 1. 704-1(b)(2)
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SPECIAL TAX ELECTIONS. With respect to Sec. 4.1, the Parties agree (if not applicable insert "N/A" or strike): ========================================================================================================= e) that the Partnership shall elect to account for dispositions of depreciable NO assets under the general asset method to the extent permitted by Code ss. 168(i)(4); --------------------------------------------------------------------------------------------------------- f) that the Partnership shall elect under Code ss.754 to adjust the basis Upon of Partnership property, with the adjustments provided in Code ss.734 for a any distribution of property and in Code ss.743 for a transfer of a partnership Party's interest. In case of distribution of property the TRP shall adjust all tax basis written capital accounts. In the case of a transfer of a partnership interest the requet acquiring party (ies) shall establish and maintain its (their) tax basis capital account(s); --------------------------------------------------------------------------------------------------------- g) that the Partnership shall elect under Code ss.6231 to be subject to the TEFRA rules. NO ========================================================================================================= ========================================================================================================= With respect to Sec. 4.2, Depletion the Parties agree that the Partnership shall NO use simulated percentage depletion instead of simulated cost depletion. ========================================================================================================= JOA - Exhibit "F"
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SPECIAL TAX ELECTIONS. With respect to Section 4.1, the Parties agree as follows: (a) that the Tax Partnership shall elect to account for dispositions of depreciable assets under the general asset method to the extent permitted by Code 168(i)(4); No (b) that, upon the request of either Party, the Tax Partnership shall elect under Code 754 to adjust the basis of Tax Partnership property, with the adjustments provided in Code 734 for a distribution of property and in Code 743 for a transfer of a partnership interest. In case of distribution of property, the TRP shall adjust all tax basis capital accounts; Yes (c) that the Tax Partnership shall elect under Code 6231 to be subject to the TEFRA rules; N/A (d) With respect to Section 4.2, Depletion the Parties agree that the Tax Partnership shall use simulated percentage depletion instead of simulated cost depletion; No (e) With respect to Section 5.2.4, under the rules of Treas. Reg. 1.704-1(b)(2)(iv)(f) the Parties agree that the FMV capital accounts shall be revalued to reflect value changes of the Tax Partnership property upon the occurrence of the events specified in (5)(i) through (iii) of said -1(b)(2)(iv)(f) regulations; and Yes (f) With respect to Section 6.2.8, the income attributable to take-in-kind production will be reflected on the tax return. Yes With respect to Section 5.2.3 the FMV for the listed property or properties are determined as follows: Eco Xxxxxxx Lease $80,705.92
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SPECIAL TAX ELECTIONS. With respect to Sec. 4.1, the Parties agree (if not applicable insert "N/A" or strike): ----------------------------------------------------------------------------------------------- e) that the Partnership shall elect to account for dispositions of depreciable NO assets under the NO general asset method to-the extent permitted by Code 168(i)(4); ----------------------------------------------------------------------------------------------- f) that the Partnership shall elect under Code ss.754 to adjust the basis of Upon Partnership property, with the adjustments provided in Code ss.734 for a any distribution of property and in Code ss.743 for a transfer of a partnership Party's interest. In case of distribution of property the TRP shall adjust all tax basis written capital accounts. In the case of a transfer of a partnership interest the request acquiring party(ies) shall establish and maintain its (their) tax basis capital account(s); ----------------------------------------------------------------------------------------------- g) that the Partnership shall elect under Code ss.6231 to be subject to the NO TEFRA rules. -----------------------------------------------------------------------------------------------
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Related to SPECIAL TAX ELECTIONS

  • SPECIAL TAX ELECTION The acquisition of the Purchased Shares may result in adverse tax consequences which may be avoided or mitigated by filing an election under Code Section 83(b). Such election must be filed within thirty (30) days after the date of this Agreement. A description of the tax consequences applicable to the acquisition of the Purchased Shares and the form for making the Code Section 83(b) election are set forth in Exhibit II. OPTIONEE SHOULD CONSULT WITH HIS OR HER TAX ADVISOR TO DETERMINE THE TAX CONSEQUENCES OF ACQUIRING THE PURCHASED SHARES AND THE ADVANTAGES AND DISADVANTAGES OF FILING THE CODE SECTION 83(b) ELECTION. OPTIONEE ACKNOWLEDGES THAT IT IS OPTIONEE'S SOLE RESPONSIBILITY, AND NOT THE CORPORATION'S, TO FILE A TIMELY ELECTION UNDER CODE SECTION 83(b), EVEN IF OPTIONEE REQUESTS THE CORPORATION OR ITS REPRESENTATIVES TO MAKE THIS FILING ON HIS OR HER BEHALF.

  • Income Tax Elections In the event of a distribution of property made in the manner provided under Section 734 of the Code, or in the event of a transfer of any Partnership Interest permitted by this Agreement made in the manner provided in Section 743 of the Code, the General Partner, on behalf of the Partnership, may, but shall not be required to, file an election under Section 754 of the Code in accordance with the procedures set forth in the applicable regulations promulgated thereunder.

  • Tax Elections Except as otherwise provided herein, the General Partner shall, in its sole and absolute discretion, determine whether to make any available election pursuant to the Code, including the election under Section 754 of the Code. The General Partner shall have the right to seek to revoke any such election (including without limitation, any election under Section 754 of the Code) upon the General Partner’s determination in its sole and absolute discretion that such revocation is the best interests of the Partners.

  • Tax Election This statement is being made under Section 83(b) of the Internal Revenue Code, pursuant to Treas. Reg.

  • Special Tax Treatment Capital gains treatment and 10-year forward income averaging authorized by IRC Sec. 402 do not apply to IRA distributions.

  • Federal Income Tax Elections The Member shall make all elections for federal income tax purposes.

  • Income Tax Allocations (a) Except as provided in this Section 9.4, each item of income, gain, loss and deduction of the Company for federal income tax purposes shall be allocated among the Members in the same manner as such items are allocated for book purposes under Sections 9.1, 9.2, 9.3 and 13.4(b). (b) In accordance with Code Section 704(c) and the applicable Treasury Regulations thereunder, income, gain, loss and deduction with respect to any property contributed to the Company shall, solely for tax purposes, be allocated among the Members so as to take account of any variation between the adjusted basis of such property to the Company for federal income tax purposes and its Gross Asset Value at the time of its contribution to the Company. If the Gross Asset Value of any Company property is adjusted in accordance with clause (c) or (d) of the definition of Gross Asset Value, then subsequent allocations of income, gain, loss and deduction shall take into account any variation between the adjusted basis of such property for federal income tax purposes and its Gross Asset Value as provided in Code Section 704(c) and the related Treasury Regulations. For purposes of such allocations, the Company shall elect the remedial allocation method described in Treasury Regulation Section 1.704-3(d). (c) All items of income, gain, loss, deduction and credit allocated to the Members in accordance with the provisions hereof and basis allocations recognized by the Company for federal income tax purposes shall be determined without regard to any election under Section 754 of the Code which may be made by the Company. (d) If any deductions for depreciation or cost recovery are recaptured as ordinary income upon the Transfer of Company properties, the ordinary income character of the gain from such Transfer shall be allocated among the Members in the same ratio as the deductions giving rise to such ordinary character were allocated.

  • Annual Tax Information The Managers shall cause the Company to deliver to the Member all information necessary for the preparation of the Member’s federal income tax return.

  • Income Tax Returns Borrower has no knowledge of any pending assessments or adjustments of its income tax payable with respect to any year.

  • Company Tax Returns The Company shall file all tax returns, if any, required to be filed by the Company.

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