英语翻译
Allocations for Tax Purposes.The Company’s ordinary income and losses,capital gains and losses and other items as determined for United States federal income tax purposes (and each item of income,gain,loss or deduction entering into the computation thereof) shall be allocated to the Shareholders in the same proportions as the corresponding “book” items are allocated pursuant to Sections 1.03 and 1.04.Notwithstanding the foregoing sentence,United States federal income tax items relating to any Section 704(c) Property shall be allocated among the Shareholders in accordance with the principles of Section 704(c) of the Code and Treasury Regulations Sections 1.704-1(b)(2)(iv)(f) and (g),1.704-1(b)(4)(i) and 1.704-3(e) to take into account the difference between the fair market value and the tax basis of such Section 704(c) Property as of the date of its revaluation pursuant to Section 1.02(b) or its contribution to the Company.Items described in this Section 1.06 shall neither be credited nor charged to the Shareholders’ Capital Accounts.