Section 704(c) Allocations definition

Section 704(c) Allocations means disproportionate allocations (relative to economic percentage interests of the members of the LLC) of items of taxable income, gain, loss and deduction in accordance with Treasury Regulation Section 1.704-3 with respect to Reference Inventory Assets.
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Section 704(c) Allocations means, in accordance with Treasury Regulation Section 1.704-3 and the principles thereof, allocations of items of taxable income, gain, loss and deduction to take into account any Book-Tax Disparity of any Reference Asset on the date of the Capital Contribution using the traditional method as described in Treasury Regulation Section 1.704-3(b).
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Section 704(c) Allocations means allocations of items of taxable income, gain, loss and deduction in accordance with Treasury Regulation Section 1.704-3 and the portion of any allocations of items of taxable income, gain, loss and deduction in respect of a Pre-Contribution Asset by the Hunters Point Venture that would be allocable pursuant to Treasury Regulation Section 1.704-3 if the capital accounts of the Hunters Point Venture were revalued in accordance with the principles of Treasury Regulation Section 1.704-1(b)(2)(iv)(f) on the Effective Date.
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Examples of Section 704(c) Allocations in a sentence

  • Section 2.1. Basis Adjustments and Section 704(c) Allocations; The LLC 754 Election.

  • Except as otherwise required by law, all calculations and determinations made hereunder, including, without limitation, any Basis Adjustments, Reverse Section 704(c) Allocations, the Schedules, and the determination of any Realized Tax Benefits or Realized Tax Detriments, shall be made in accordance with the elections, methodologies or positions taken by the Corporation and Xxxx Holdings on their respective Tax Returns.

  • All calculations and determinations made hereunder, including, without limitation, any Basis Adjustments, Reverse Section 704(c) Allocations, the Schedules, and the determination of any Realized Tax Benefits or Realized Tax Detriments, shall be made in accordance with the elections, methodologies or positions taken by the Corporation and Xxxx Holdings on their respective Tax Returns.

  • Amendments to Appendix C following any issuance, redemption, repurchase, reallocation or Transfer of Units in accordance with this Agreement, and any amendments made pursuant to Appendix B (other than Section 118 (Section 704(c) Allocations) or Section 120 (Warrant or Option) or Appendix C may be made by the Company with the consent of the Members holding a majority of the outstanding Series A Preferred Units.

  • In the event we issue additional units or engage in certain other transactions in the future, “reverse Section 704(c) Allocations,” similar to the Section 704(c) Allocations described above, will be made to all of our unitholders immediately prior to such issuance or other transactions to account for the difference between the “book” basis for purposes of maintaining capital accounts and the fair market value of all property held by us at the time of such issuance or future transaction.

  • With respect to (i) property contributed by a Partner, and (ii) any “reverse Code section 704(c) allocations” resulting from the revaluation of Partnership property pursuant to Regulations Section 1.704-1(b)(2)(iv)(f) and any post-Effective Date Section 704(c) Allocations (collectively the “Section 704(c) Allocations”), the various allocation methods set forth in Exhibit 4.6.1 attached hereto shall apply with respect to any such Section 704(c) Allocations.

  • BRC shall elect the method ---------------------------------- under which Reverse Section 704(c) Allocations will be made for each item of property whose Asset Value is so adjusted.

  • Section 6.13 - Section 704(c) Allocations..................................

  • Section 6.1. Allocations of Tax Book Profits and Tax Book Losses 29 Section 6.2. Allocations for Tax Purposes 30 Section 6.3. Certain Accounting Matters 30 Section 6.4. Section 704(c) Allocations 30 Section 6.5. Qualified Income Offset 30 Section 6.6. Gross Income Allocation 31 Section 6.7. LLP Minimum Gain Chargeback 31 Section 6.8. Member Nonrecourse Debt Minimum Gain Chargeback 31 Section 6.9. Limitations on Tax Book Loss Allocations 31 Section 6.10.


More Definitions of Section 704(c) Allocations

Section 704(c) Allocations has the meaning set forth in Section 6.05(b).
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Related to Section 704(c) Allocations

  • Required Allocations means (a) any limitation imposed on any allocation of Net Losses or Net Termination Losses under Section 6.1(b) or 6.1(c)(ii) and (b) any allocation of an item of income, gain, loss or deduction pursuant to Section 6.1(d)(i), 6.1(d)(ii), 6.1(d)(iv), 6.1(d)(vii) or 6.1(d)(ix).

  • Tax Allocations means the allocations set forth in paragraph 4 of Exhibit B.

  • Allocations means any and all of the allocations described in Sections 1.3(a), 1.3(b), 1.3(c) and 1.3(d) hereof.

  • Final Allocation has the meaning set forth in Section 2.3.

  • Taxable Allocation means, with respect to any Series, the allocation of any net capital gains or other income taxable for federal income tax purposes to a dividend paid in respect of such Series.

  • Curative Allocation means any allocation of an item of income, gain, deduction, loss or credit pursuant to the provisions of Section 6.1(d)(xi).

  • Asset Allocation The following single issuer limits shall apply on a market value basis, with exception of Money-Market funds and US Government guaranteed securities, which may be held without limit:

  • Class B Fixed Allocation means, with respect to any Monthly Period following the Revolving Period, the percentage equivalent (which percentage shall never exceed 100%) of a fraction, the numerator of which is the Class B Investor Interest as of the close of business on the last day of the Revolving Period and the denominator of which is equal to the Investor Interest as of the close of business on the last day of the Revolving Period.

  • Initial Allocation means the conditional setting aside by MBOH of HCs from a particular year’s federal LIHTC allocation to the state for purposes of later Carryover Commitment and/or Final Allocation to a particular Project, as documented by and subject to the requirements and conditions set forth in a written Reservation Agreement, the Applicable QAP and federal law.

  • Allocation shall have the meaning set forth in Section 2.7.

  • Carryover Allocation means an Allocation made to the Project if the Project will not be Placed in Service by close of the calendar year of the Allocation.

  • Capital Accounts An individual capital account shall be maintained for each Partner, and capital contributions to the Partnership by the Partners shall be credited to such accounts. Partnership profits or losses shall also be charged or credited to the separate capital accounts in the manner provided in this Agreement. No interest shall be paid on the capital account of any Partner.

  • After-Tax Contributions means amounts withheld from an Employee’s Compensation pursuant to a Salary Reduction Agreement after all applicable state and federal taxes have been deducted. Such amounts are withheld for purposes of purchasing one or more of the Benefit Package Options available under the Plan.

  • Capital Account Limitation has the meaning set forth in Section 4.05(b) hereof.

  • Agreed Allocation means any allocation, other than a Required Allocation, of an item of income, gain, loss or deduction pursuant to the provisions of Section 6.1, including a Curative Allocation (if appropriate to the context in which the term “Agreed Allocation” is used).

  • Adjusted Capital Account Deficit means, with respect to any Member, the deficit balance, if any, in such Member’s Capital Account as of the end of the relevant Fiscal Year, after giving effect to the following adjustments:

  • Percentage Allocation is defined in Section 4.3(b)(ii)(y).

  • Loss Allocation Limitation As defined in Section 4.4(g).

  • Simulated Gain means the excess of the amount realized from the sale or other disposition of an oil or gas property over the Carrying Value of such property.

  • Allocation Year Means (i) the period commencing on the Closing Date and ending on December 31, 2006, (ii) any subsequent period commencing on January 1 and ending on the following December 31, or (iii) any portion of the period described in clause (ii) for which the Company is required to allocate Profits, Losses and other items of Company income, gain, loss or deduction pursuant to Article V.

  • Regulatory Allocations shall have the meaning set forth in Section 6.3.A(viii).

  • Tax Allocation Agreement means the Tax Allocation Agreement between Corporation and New D&B.