Tax Allocation Matters. 18 (a) Contributed or Revalued Property........................................................18 (b) Recapture Items.........................................................................19 6.11
Tax Allocation Matters. (a) Except as otherwise provided in this Section 4.10, all items of income, gain, loss deduction or credit for federal, state and local income tax purposes will be allocated in the same manner as the corresponding “book” items are allocated under Sections 4.1 (as a component of Net Income or Net Losses), or 6.2.
Tax Allocation Matters. (a) CONTRIBUTED OR REVALUED PROPERTY. Each Member's allocable share of the taxable income or loss of the Company, depreciation, depletion, amortization and gain or loss with respect to any contributed property, or with respect to revalued property where the Company's property is revalued pursuant to Paragraph (b)(2)(iv)(f) of Section 1.704-1 of the Treasury Regulations, shall be determined in the manner (and as to revaluations, in the same manner as) provided in Section 704(c) of the Code. The allocation shall take into account, to the full extent required or permitted by the Code, the difference between the adjusted basis of the property to the Member contributing it and the fair market value of the property determined by the Managers at the time of its contribution or revaluation, as the case may be. The Company shall apply Section 704(c)(1)(A) by using the "traditional method" as set forth in Section 1.704-3(b) of the Treasury Regulations.
Tax Allocation Matters. (i) The parties hereto agree to allocate the Estimated Purchase Price and the Assumed Liabilities (and any Liabilities considered assumed by the Buyers treated as purchase consideration for Tax purposes) as among the Sellers and (1) as apportioned between the Purchased Assets, on the one hand, and the Foreign Securities, on the other, with (2) the amount so apportioned to the Foreign Securities further allocated among the Foreign Subsidiaries, as set forth in Exhibit G (the “Seller Level Allocation”).
Tax Allocation Matters. (a) Each Member’s allocable share of Company taxable income or loss, depreciation, depletion, amortization, or gain or loss with respect to any contributed property, or with respect to Company property that is revalued pursuant to Treasury Regulations § 1.704-1(b)(2)(iv)(f) and (g) or Section 1.8, shall be determined in the manner (and as to revaluations, in the same manner as) provided in Section 704(c) of the Code. The allocation shall take into account, to the full extent required or permitted by the Code, the difference between the adjusted basis of the property to the Member contributing (or deemed to be contributing) it and the Fair Market Value of the property at the time of its contribution or revaluation, as the case may be, as determined by the Manager. Company shall apply Section 704(c)(1)(A) by using any method chosen by the Manager which is permissible by applicable law.
Tax Allocation Matters
