EFTA Document EFTA01357708

(a) The fair market value of such member's initial capital contribution and any additional capital contributions by such member. If any property, other than cash, is contributed to or distributed by the Company, the adjustments to Capital Accounts required by Treasury Regulation Section 1.704-1(bX2XivXd), (e), (f) and (g) and Section 1.704-1(b)(4)(1) shall be made. (b) The member's share of the increase in the tax basis of Company property, if any, arising out of the recapture of any tax