Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section 734(b) or 743(b) is required, pursuant to Section 1.704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4) of the Regulations, to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of his or its interest in the Company, the amount of such adjustment to Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Members in accordance with their Interests if such Section 1.704-1(b)(2)(iv)(m)(2) applies, or, if such Section 1.704-1(b)(2)(m)(4) applies, to the Member to whom such distribution was made.
Appears in 6 contracts
Sources: Operating Agreement (Decrane Holdings Co), Operating Agreement (Decrane Aircraft Holdings Inc), Operating Agreement (Decrane Aircraft Holdings Inc)
Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset property pursuant to Code Section 734(b) or Code Section 743(b) is required, required pursuant to Regulations Section 1.704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4) of the Regulations, to be taken into account in determining Capital Accounts as the result of a distribution to a Member member in complete liquidation of his or its interest in the CompanyInterest, the amount of such adjustment to Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Members members in accordance with their Interests if such interests in the Company in the event Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or, if such Section 1.704-1(b)(2)(m)(4) applies, or to the Member member to whom such distribution was mademade in the event Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.
Appears in 5 contracts
Sources: Operating Agreement (Great Plains Energy Inc), Operating Agreement (Entergy Arkansas Inc), Operating Agreement (Dominion Resources Inc /Va/)
Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(4) of the Regulations), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of his or its interest in the Company, the amount of such adjustment to Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Members in accordance with their respective Percentage Interests if such in the Company in the event that Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or, if such Section 1.704-1(b)(2)(m)(4) applies, or to the Member to whom such distribution was mademade in the event that Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.
Appears in 4 contracts
Sources: Framework Agreement (MPG Office Trust, Inc.), Limited Liability Company Agreement (Regency Centers Corp), Limited Liability Company Agreement (Regency Centers Lp)