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 has the meaning set forth in Section 6.05(b).
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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.

  • 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.

  • 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.

  • 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.

  • However, it may not be administratively feasible to make the relevant adjustments to “book” basis and the relevant reverse Section 704(c) Allocations each time we issue common units, particularly in the case of small or frequent common unit issuances.

  • With respect to (i) property contributed by the Xxxxxxxx Partners prior to the Effective Date, 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 Board of Directors shall determine the Code Section 704(c) method with respect to any such Section 704(c) Allocations.

  • 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.

  • 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.

  • 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 to be elected pursuant to Exhibit 4.5.1 attached hereto shall apply with respect to any such Section 704(c) Allocations.


More Definitions of Section 704(c) Allocations

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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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.

  • Wasteload allocation or "wasteload" or "WLA" means the portion of a receiving surface water's loading or assimilative capacity allocated to one of its existing or future point sources of pollution. WLAs are a type of water quality-based effluent limitation.

  • 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 Treasury Bills, which may be held without limit:

  • 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 has the meaning set forth in Section 3.3.

  • Waste load allocation means (i) the water quality-based annual mass load of total nitrogen or

  • 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 provided in Section 4.5(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).

  • Reais Allocation Date means, with respect of any Reais Transfer Date, the Business Day which is immediately prior to such Reais Transfer Date.

  • 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:

  • conditional allocation ’ means an allocation to a province or municipality from the national government’s share of revenue raised nationally, envisaged in section 214(1)(c) of the Constitution, as set out in Schedule 4, 5, 6 or 7;

  • 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.

  • Tax-Related Losses means (i) all federal, state, local and foreign Taxes (including interest and penalties thereon) imposed (or that would be imposed) pursuant to any settlement, Final Determination, judgment or otherwise, (ii) all accounting, legal and other professional fees, and court costs incurred in connection therewith, and (iii) all costs, expenses and damages associated with stockholder litigation or controversies and any amount paid by Parent (or any Parent Affiliate) or SpinCo (or any SpinCo Affiliate) in respect of the liability of shareholders, whether paid to shareholders or to the IRS or any other Tax Authority, in the case of each of clauses (i) through (iii), resulting from the failure of the Internal Distribution, the Contribution or the Distribution to have Tax-Free Status.