Common use of Company Minimum Gain Chargeback Clause in Contracts

Company Minimum Gain Chargeback. Notwithstanding the other provisions of this Article IV, except as provided in Treasury Regulation Section 1.704-2(f), if there is a net decrease in Company Minimum Gain during any Taxable Year, each Member shall be specially allocated items of Company income and gain for such Taxable Year (and, if necessary, subsequent Taxable Years) in an amount equal to such Member’s share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulation Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation Sections 1.704-2(f)(6) and 1.704-2(j)(2). This Section 4.3(a) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding the other provisions of this Article IV, except as provided in Treasury Regulation Regulations Section 1.704-2(f1.704‑2(f), if there is a net decrease in Company Minimum Gain during any Taxable Yeartaxable year of the Company, each Member shall be specially allocated items Company Items of Company income and gain for such Taxable Year taxable year (and, if necessary, necessary subsequent Taxable Yearstaxable years) in an amount equal to such Member’s share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulation Regulations Section 1.704-2(g1.704‑2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items Company Items to be so allocated shall be determined in accordance with Treasury Regulation Regulations Sections 1.704-2(f)(61.704‑2(f)(6) and 1.704-2(j)(21.704‑2(j)(2). This Section 4.3(a) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation Regulations Section 1.704-2(f1.704‑2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding the other provisions of this Article IV, except as provided in Treasury Regulation Regulations Section 1.704-1.704 2(f), if there is a net decrease in Company Minimum Gain during any Taxable Yeartaxable year of the Company, each Member shall be specially allocated items Company Items of Company income and gain for such Taxable Year taxable year (and, if necessary, necessary subsequent Taxable Yearstaxable years) in an amount equal to such Member’s share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulation Regulations Section 1.704-1.704 2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items Company Items to be so allocated shall be determined in accordance with Treasury Regulation Regulations Sections 1.704-1.704 2(f)(6) and 1.704-1.704 2(j)(2). This Section 4.3(a) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation Regulations Section 1.704-1.704 2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding the other provisions of this Article IV, except Except as otherwise provided in Treasury Regulation Regulations Section 1.704-2(f), notwithstanding any other provision of this Article VI, if there is a net decrease in Company Minimum Gain during any Taxable Fiscal Year, each Member Unitholder shall be specially allocated items of Company income and gain for such Taxable Fiscal Year (and, if necessary, subsequent Taxable Fiscal Years) in an amount equal to such Member’s Unitholder's share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulation Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member Unitholder pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2). This Section 4.3(a6.2(d)(i) is intended to comply with the minimum gain chargeback requirement requirements set forth in Treasury Regulation Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding the other provisions of this Article IV, except Except as otherwise provided in Treasury Regulation Section 1.704-2(f)) of the Treasury Regulations, notwithstanding any other provision of this Agreement, if there is a net decrease in Company Minimum Gain during any Taxable YearCompany fiscal year, each Member shall be specially allocated items of Company income and gain for such Taxable Year fiscal year (and, if necessary, subsequent Taxable Yearsfiscal years) in an amount equal to such Member’s share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulation Section 1.704-2(g)) of the Treasury Regulations. Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation Sections 1.704-2(f)(6) and 1.704-2(j)(2)) of the Treasury Regulations. This Section 4.3(aC1(b)(i) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation Section 1.704-2(f) of the Treasury Regulations and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding the other provisions of this Article IV, except Except as otherwise provided in Treasury Regulation Regulations Section 1.704-2(f), notwithstanding anything herein to the contrary, if there is a net decrease in Company Minimum Gain during any Taxable Fiscal Year, each Member shall be specially allocated items of Company income and gain for such Taxable Fiscal Year (and, if necessary, subsequent Taxable Fiscal Years) in an amount equal to such Member’s share of the such net decrease in Company Minimum GainGain during such Fiscal Year, determined in accordance with Treasury Regulation Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation Regulations Sections 1.704-2(f)(61.704‑2(f)(6) and 1.704-2(j)(2). This Section 4.3(a7.2(a) is intended to comply with the minimum gain chargeback requirement requirements in Treasury Regulation Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding the other provisions of this Article IVSection 5.01, except as provided in Treasury Regulation Section 1.704-2(f), if there is a net decrease in Company Minimum Gain during any Taxable Allocation Year, each Member shall be specially allocated items of Company income and gain for such Taxable Allocation Year (and, if necessary, necessary subsequent Taxable Allocation Years) in an amount equal to such Member’s share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulation Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation Sections 1.704-2(f)(6) and 1.704-2(j)(2). This Section 4.3(a5.01(b)(i) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding the any other provisions provision of this Article IV, except as provided in Treasury Regulation Section 1.704-2(f)4.3, if there is a net decrease in Company Minimum Gain during any Taxable YearFiscal Year or Fiscal Period, each Member shall be specially allocated items of Company income and gain (as specified in Treasury Regulation Section 1.704-2(f)(6)) for such Taxable Fiscal Year or Fiscal Period (and, if necessary, for subsequent Taxable Yearsperiods, as provided in Treasury Regulation Section 1.704-2(j)(2)(iii)) in an amount equal to the portion of such Member’s share of the net decrease in such Company Minimum Gain, determined in accordance with Treasury Regulation Section 1.704-2(g2(g)(2). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items of income and gain to be so specially allocated pursuant to this Section 4.3(a) shall be determined in accordance with Treasury Regulation Sections Section 1.704-2(f)(6) and 1.704-2(j)(22(f). This Section 4.3(a) is intended to comply with the minimum gain chargeback requirement in of Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding the any other provisions provision of this Article IVAgreement, except as otherwise provided in Treasury Regulation Section 1.704-2(fRegulations § 1.704–2(f), if there is a net decrease in Company Minimum Gain during any Taxable Allocation Year, each Member shall be specially allocated items of Company income and gain for such Taxable the Allocation Year (and, if necessary, subsequent Taxable Allocation Years) in an amount equal to such Member’s share of the net decrease in Company Minimum Gainminimum gain, determined in accordance with Treasury Regulation Section 1.704-2(gRegulations § 1.704–2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation Sections 1.704-2(f)(6Regulations §§ 1.704–2(f)(6) and 1.704-2(j)(21.704–2(j)(2). This Section 4.3(a4.2(a) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation Section 1.704-2(fRegulations § 1.704–2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding the other provisions of this Article IV, except Except as otherwise provided in Treasury Regulation Section Regulations §1.704-2(f), notwithstanding any other provision of this Article V, if there is a net decrease in Company Minimum Gain during any Taxable Fiscal Year, each Member shall be specially allocated items of Company income and gain for such Taxable Fiscal Year (and, if necessary, subsequent Taxable Fiscal Years) in an amount equal to such Member’s share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulation Section Regulations §1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation Sections Regulations §§1.704-2(f)(6) and 1.704-2(j)(2). This Section 4.3(a5.2(a) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation Section Regulations §1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding the other provisions of this Article IV, except Except as otherwise provided in Treasury Regulation Regulations Section 1.704-2(f), notwithstanding any other provision of this Article XI, if there is a net decrease in Company Minimum Gain during any Taxable YearAccounting Period, each Member shall be specially allocated items of Company income and gain for such Taxable Year Accounting Period (and, if necessary, subsequent Taxable YearsAccounting Periods) in an amount equal to such Member’s 's share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulation Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2). This Section 4.3(a11.2(c) is intended to comply with the minimum gain chargeback requirement requirements set forth in Treasury Regulation Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding the other provisions of this Article IV, except Except as otherwise provided in Treasury Regulation Section 1.704-2(f), notwithstanding any other provision of this Article 5, if there is a net decrease in Company Minimum Gain during any Taxable Yearfiscal year, each Member shall be specially allocated items of Company income and gain for such Taxable Year fiscal year (and, if necessary, subsequent Taxable Yearsfiscal years) in an amount equal to such Member’s share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulation Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation Sections 1.704-2(f)(6) and 1.704-2(j)(2). This Section 4.3(a5.05(a) is intended to comply with the partnership minimum gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted and applied consistently therewith.