Company Minimum Gain. Except as otherwise provided in Regulations Section 1.704-2(f), if there is a net decrease in Company Minimum Gain during any Company taxable period, each Member shall be specially allocated items of Company income and gain for such period (and, if necessary, subsequent periods) in proportion to and to the extent of, an amount equal to the portion of such Member’s share of the net decrease in Company Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). This Section 7.1(c)(ii) is intended to comply with the charge back of items of income and gain requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.
Appears in 3 contracts
Samples: Redemption Agreement (Energy Transfer Equity, L.P.), Purchase and Sale Agreement (Energy Transfer Partners, L.P.), Limited Liability Company Agreement (Southern Union Co)
Company Minimum Gain. Except as otherwise provided in Regulations Section 1.704-2(f), if there is a net decrease in Company Minimum Gain during any Company taxable periodFiscal Year, each Member shall be specially allocated items of Company income and gain for such period Fiscal Year (and, if necessary, subsequent periodsFiscal Years) in proportion to and to the extent of, an amount equal to the portion of such Member’s 's share of the net decrease in Company Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). This Article VII, Section 7.1(c)(ii2(a) is intended to comply with the charge back chargeback of items of income and gain requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.
Appears in 2 contracts
Samples: Limited Liability Company Operating Agreement (Shipyard River Coal Terminal Co), Limited Liability Company Operating Agreement (Shipyard River Coal Terminal Co)
Company Minimum Gain. Except as otherwise provided in Regulations Section 1.704-2(f), if there is a net decrease in Company Minimum Gain during any Company taxable period, each Member shall be specially allocated items of Company income and gain for such period (and, if necessary, subsequent periods) in proportion to and to the extent of, an amount equal to the portion of such Member’s 's share of the net decrease in Company Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). This Section 7.1(c)(ii) is intended to comply with the charge back of items of income and gain requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Southern Union Co)
Company Minimum Gain. Except as otherwise provided in Regulations Section 1.704-2(f), if there is a net decrease in Company Minimum Gain during any Company taxable period, each Member shall be specially allocated items of Company income and gain for such period (and, if necessary, subsequent periods) in proportion to and to the extent of, an amount equal to the portion of such Member’s share of the net decrease in Company Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). This Section 7.1(c)(ii) is intended to comply with the charge back chargeback of items of income and gain requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.
Appears in 1 contract
Samples: Agreement to Form Limited Liability Company and Contribution Agreement (Empire Resorts Inc)
