Tax and Regulatory Compliance. 1. Income, gain, loss and deductions shall be allocated for income tax purposes generally in the manner in which the corresponding Profit and Loss is credited or debited (as the case may be) to their respective Capital Accounts; provided, however, that any difference between the Adjusted Asset Value and adjusted tax basis of any asset shall be reconciled, solely for income tax purposes, in accordance with the principles of Code Section 704(c) using any method permitted by the Treasury Regulations and selected by the Manager.
Appears in 4 contracts
Samples: Operating Agreement, Operating Agreement, Operating Agreement
Tax and Regulatory Compliance. 1. Income, gain, loss and deductions shall be allocated for income tax purposes generally in the manner in which the corresponding Profit Profit and Loss is credited or debited (as the case may be) to their respective Capital Accounts; provided, however, that any difference difference between the Adjusted Asset Value and adjusted tax basis of any asset shall be reconciled, solely for income tax t ax purposes, in accordance with the principles of Code Section 704(c) using any method permitted by the Treasury Regulations and selected by the Manager.
Appears in 4 contracts
Samples: Operating Agreement, Operating Agreement, Operating Agreement
Tax and Regulatory Compliance. 1. Income, gain, loss and deductions shall be allocated for income tax purposes generally in the manner in which the corresponding Profit Profit and Loss is credited or debited (as the case may be) to their respective Capital Accounts; provided, however, that any difference difference between the Adjusted Asset Value and adjusted tax basis of any asset shall be reconciled, solely for income tax purposes, in accordance with the principles of Code Section 704(c) using any method permitted by the Treasury Regulations and selected by the Manager.
Appears in 3 contracts
Samples: Operating Agreement, Operating Agreement, Operating Agreement