Section 754 Adjustment. To the extent that an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Regulations Section 1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Holder of Partnership Units in complete liquidation of its interest in the Partnership, the amount of such adjustment to the 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 applicable Holders in accordance with the aforesaid Regulations.
Appears in 7 contracts
Sources: Limited Partnership Agreement (Pacific Office Properties Trust, Inc.), Partnership Agreement (Arizona Land Income Corp), Limited Partnership Agreement (Newkirk Realty Trust, Inc.)
Section 754 Adjustment. To the extent that an adjustment to the adjusted tax basis of any Partnership Company asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m)(21(b) (2)(iv)(m)(2) or Regulations Section 1.704-1(b)(2)(iv)(m)(41(b) (2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Holder of Partnership Units Member in complete liquidation of its interest in the PartnershipCompany, the amount of such adjustment to the 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 applicable Holders Members in accordance with their LLC Units in the aforesaid Regulations.event that Regulations Section 1.704-1(b) (2)(iv)(m)
Appears in 3 contracts
Sources: Limited Liability Company Agreement (Health Care Property Investors Inc), Limited Liability Company Agreement (Pan Pacific Retail Properties Inc), Operating Agreement (Pan Pacific Retail Properties Inc)
Section 754 Adjustment. To the extent that an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Regulations Section 1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Holder of Partnership Units in complete liquidation of its interest in the Partnership, the amount of such adjustment to the 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 applicable Holders in accordance with their interests in the aforesaid Regulations.Partnership in the event that Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the
Appears in 3 contracts
Sources: Agreement of Limited Partnership (Hudson Pacific Properties, Inc.), Agreement of Limited Partnership (Hudson Pacific Properties, Inc.), Limited Partnership Agreement (Hudson Pacific Properties, Inc.)
Section 754 Adjustment. To the extent that an adjustment to the adjusted tax basis of any Partnership 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 1.704-1.704- 1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution Distribution to a Holder of Partnership Units Member in complete liquidation of its his interest in the PartnershipCompany, the amount of such adjustment to the 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 applicable Holders Members in accordance with their interests in the aforesaid Regulations.Company in the event that Treasury Regulations Section 1.704-1(b)(2)(iv)(m)
Appears in 2 contracts
Sources: Operating Agreement (Prime Medical Services Inc /Tx/), Operating Agreement (Prime Medical Services Inc /Tx/)
Section 754 Adjustment. To the extent that an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Regulations Section 1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Holder of Partnership Common Units in complete liquidation of its interest in the Partnership, the amount of such adjustment to the 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 applicable Holders in accordance with their respective Percentage Interests in the aforesaid Regulations.event that Regulations Section 1.704-1(b)(2)(iv)(m)
Appears in 2 contracts
Sources: Agreement of Limited Partnership (Hammons John Q Hotels Inc), Limited Partnership Agreement (Hammons John Q Hotels Inc)
Section 754 Adjustment. To the extent that an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Regulations Section 1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Holder of Partnership Units in complete liquidation of its interest in the Partnership, the amount of such adjustment to the 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 applicable Holders in accordance with the aforesaid Regulations.or
Appears in 1 contract
Sources: Asset Purchase Agreement (Hudson Pacific Properties, Inc.)
Section 754 Adjustment. To the extent that an adjustment to the adjusted tax basis of any Partnership 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)(21(b) (2) (iv) (m) (2) or Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(41(b) (2) (iv) (m) (4), to be taken into account in determining Capital Accounts as the result of a distribution to a Holder of Partnership Units Member in complete liquidation of its interest in the PartnershipCompany, the amount of such adjustment to the 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 applicable Holders Members in accordance with their Percentage Interests in the aforesaid Regulations.event that Treasury Regulations Section 1.704-1(b) (2) (iv) (m)
Appears in 1 contract
Sources: Agreement of Limited Liability Company (T&w Financial Corp)
Section 754 Adjustment. To the extent that an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m)(21(b)(2) (iv)(m)(2) or Regulations Section 1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Holder of Partnership Common Units in complete liquidation of its interest in the Partnership, the amount of such adjustment to the 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 applicable Holders in accordance with their respective Percentage Interests in the aforesaid Regulations.event that Regulations Section 1.704-1(b)(2)(iv)(m)
Appears in 1 contract
Section 754 Adjustment. To the extent that an adjustment to ---------------------- the adjusted tax basis of any Partnership Company asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Regulations Section 1.704-1.704- 1(b)(2)(iv)(m)(2) or Regulations Section 1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Holder of Partnership Units Member in complete liquidation of its interest in the PartnershipCompany, the amount of such adjustment to the 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 applicable Holders Members in accordance with their LLC Units in the aforesaid Regulations.event
Appears in 1 contract
Sources: Limited Liability Company Agreement (Bre Properties Inc /Md/)
Section 754 Adjustment. To the extent that an adjustment to the adjusted tax basis of any Partnership Company asset pursuant to Code Section 734(b) of the Code or Code Section 743(b) of the Code is required, pursuant to Regulations Section section 1.704-1(b)(2)(iv)(m)(2) or Regulations Section section 1.704-1(b)(2)(iv)(m)(41(b)(2) (iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Holder of Partnership Class A Common Units in complete liquidation of its interest in the PartnershipCompany, the amount of such adjustment to the 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 applicable Holders in accordance with the aforesaid Regulations.of Class A Common Units
Appears in 1 contract