Allocations Required by Treasury Regulations. (i) (A) Subject to the exceptions set forth in Treas. Reg. §§1.7042(f)(2)-(5), if there is a net decrease in Minimum Gain during any fiscal year, each Partner shall be specially allocated items of Partnership income and gain for such year (and, if necessary, subsequent years) in an amount equal to such Partner’s share of the net decrease in Minimum Gain, determined in accordance with Treas. Reg. §1.704-2(g)(2). “
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Samples: www.sec.gov, Adesa California, LLC
Allocations Required by Treasury Regulations. (i) (Aa) Subject to the exceptions set forth in Treas. Reg. §§1.7042(f)(2)-(51.704-2(f)(2)—(5), if there is a net decrease in Minimum Gain during any fiscal yearFiscal Year, each Partner Member shall be specially allocated items of Partnership Company income and gain for such year (and, if necessary, subsequent years) in an amount equal to such PartnerMember’s share of the net decrease in Minimum Gain, determined in accordance with Treas. Reg. §1.704-2(g)(2). “
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Advanced Drainage Systems, Inc.), Limited Liability Company Agreement (American Railcar Industries, Inc.)
Allocations Required by Treasury Regulations. (i) (A) Subject to the exceptions set forth in Treas. Reg. §§1.7042(f)(2)-(51.704-2(f)(2)—(5), if there is a net decrease in Minimum Gain during any fiscal year, each Partner shall be specially allocated items of Partnership income and gain for such year (and, if necessary, subsequent years) in an amount equal to such Partner’s share of the net decrease in Minimum Gain, determined in accordance with Treas. Reg. §§ 1.704-2(g)(2). “
Appears in 1 contract
Samples: Michigan's Adventure, Inc.
Allocations Required by Treasury Regulations. (i) (A) Subject to the exceptions set forth in Treas. Reg. §§1.7042(f)(2)-(51.704-2(f)(2)—(5), if there is a net decrease in Minimum Gain during any fiscal year, each Partner Member shall be specially allocated items of Partnership Company income and gain for such year (and, if necessary, subsequent years) in an amount equal to such PartnerMember’s share of the net decrease in Minimum Gain, determined in accordance with Treas. Reg. §1.704-2(g)(2). “
Appears in 1 contract
Allocations Required by Treasury Regulations. (i) (A) Subject to the exceptions set forth in Treas. Reg. §§1.7042(f)(2)-(5§ § 1.704-2(f) (2)–(5), if there is a net decrease in Minimum Gain during any fiscal year, each Partner shall be specially allocated items of Partnership income and gain for such year (and, if necessary, subsequent years) in an amount equal to such Partner’s share of the net decrease in Minimum Gain, determined in accordance with Treas. Reg. §1.704-2(g)(2). “
Appears in 1 contract
Samples: Michigan's Adventure, Inc.
Allocations Required by Treasury Regulations. (i) (Aa) Subject to the exceptions set forth in Treas. Reg. §§1.7042(f)(2)-(51.704-2(f)(2)-(5), if there is a net decrease in Minimum Gain during any fiscal yearFiscal Year, each Partner Member shall be specially allocated items of Partnership Company income and gain for such year (and, if necessary, subsequent years) in an amount equal to such PartnerMember’s share of the net decrease in Minimum Gain, determined in accordance with Treas. Reg. §1.704-2(g)(2). “
Appears in 1 contract
Samples: Limited Liability Company Agreement (American Railcar Industries, Inc./De)
