Bcp liquidating llc
If, after the Effective Date, any Disputed General Unsecured Claim becomes an Allowed Claim, the Disbursing Agent shall, at the direction of the respective LLC Agent, on each Quarterly Distribution Date following the calendar quarter in which the Disputed General Unsecured Claim becomes an Allowed Claim, (1) distribute to the holder of such Allowed Claim Cash equal to the aggregate amount that such holder would have been entitled to receive under the Plan (if any) if such Claim had been an Allowed Claim on the Effective Date or any subsequent Distribution date and (2) with respect to any holder of a General Unsecured Claim against BCP/BCP Finance or BCPM, such holder shall continue as a BCP Liquidating LLC Claimant or BCPM Liquidating LLC Climant, as applicable, to the extent of such holders Pro Rata share of any Distribution that such holder would have been entitled to receive under the Plan had its Claim been an Allowed Claim on the Effective Date or any subsequent Distribution Date.
The proposed regulations provide that if a member with a Sec. 704(c)(1)(C) member) receives a distribution of property (whether or not the property is Sec. 704(c)(1)(C) property retained by the LLC to distributed properties of like character under the principles of Regs. 734(b) adjustment, then the negative adjustment and the Sec. 754 election solely for purposes of computing any negative Sec.
Under the terms of the agreement, a substantial portion of the purchase price of the house was provided by a loan from a related party that was immediately repaid by the retiring The IRS attacked the purported distribution based on the fact that (1) the distribution was not a distribution of partnership property since the house was acquired and held for the account of the retiring partner, (2) the distribution should be recast in accordance with the doctrine the acquisition of the house by the partnership and its distribution to the retiring partner should be disregarded, and (4) the acquisition of the house by the partnership and its distribution to the retiring partner lacked economic substance and were unnecessary steps taken solely to achieve tax A member can recognize a loss on the liquidation of his or her LLC interest if the distribution consists solely of money, unrealized receivables, and inventory and the LLC's basis in those assets is less than the member's basis in the liquidated LLC interest.