Section 754 Election definition

Section 754 Election means an election under Section 754 of the Code and any comparable election under applicable state or local income tax laws.

Section 754 Election shall have the meaning set forth in Section 8.5(a) hereof.

Section 754 Election. An election under Section 754 of the Code relating to the adjustment of the adjusted basis of Partnership Assets as provided in Sections 734 and 743 of the Code.

Examples of Section 754 Election in a sentence

• Effect of Tax Code Section 754 Election on Unit Transfers The adjusted basis of each Unit Holder in his Units, “outside basis,” initially will equal his proportionate share of our adjusted basis in our assets, “inside basis.” Over time, however, it is probable that changes in Unit values and cost recovery deductions will cause the value of a Unit to differ materially from the Unit Holder’s proportionate share of the inside basis.

• Income and deductions of the Partnership that are attributable to the Section 754 Election ("754 allocations") shall be allocated to the Partners entitled thereto.

• If at any point the Company or any of its direct or indirect Subsidiaries that is a partnership for U.S. federal income tax purposes does not have a Section 754 Election in effect, the Corporation shall cause the Company or such Subsidiary, as applicable, to make a Section 754 Election at the time that the Company or such Subsidiary, as applicable, files its next U.S. federal income Tax Return.

• The adjustments to basis to Partnership Assets that are attributable to the Section 754 Election shall be allocated to the Partners in the manner that the General Partner determines is reasonable, however, no such adjustment shall be credited or charged to the Capital Accounts.

• If at any point the Company or any of its direct or indirect Subsidiaries that is a partnership for U.S. federal income tax purposes does not have a Section 754 Election in effect, HII shall cause the Company or such Subsidiary, as applicable, to make a Section 754 Election at the time that the Company or such Subsidiary, as applicable, files its next U.S. federal income Tax Return.

More Definitions of Section 754 Election

Section 754 Election has the meaning specified in Section 6.01(b).

Section 754 Election is defined in Section 5.3.

Section 754 Election is defined in the Recitals of this Agreement.

Section 754 Election shall have the meaning specified in Section 4.11(g).

Section 754 Election means any election made by the Partnership under section 754 of the Code.

Section 754 Election has the meaning provided such term in Section 13.6.

Section 754 Election means the election described in Section 754 of the Code. “Securities Act” means the Securities Act of 1933.