Common use of LLC Minimum Gain Chargeback Clause in Contracts

LLC Minimum Gain Chargeback. Notwithstanding any other provisions of this Article X, in the event there is a net decrease in LLC Minimum Gain during an LLC fiscal year, the Members shall be allocated items of income and gain in accordance with Treasury Regulations Section 1.704-2(f). For purposes of this Article X, the term “LLC Minimum Gain” shall have the meaning for “partnership minimum gain” set forth in Treasury Regulations Section 1.704-2(b)(2), and any Member’s share of LLC Minimum Gain shall be determined in accordance with Treasury Regulations Section 1.704-2(g)(1). This Section 10.09 is intended to comply with the minimum gain chargeback requirement of Treasury Regulations Section 1.704- 2(f) and shall be interpreted and applied in a manner consistent therewith.

Appears in 3 contracts

Samples: Operating Agreement (Arvinas Holding Company, LLC), Operating Agreement (Arvinas Holding Company, LLC), Operating Agreement (Arvinas Holding Company, LLC)

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LLC Minimum Gain Chargeback. Notwithstanding any other provisions of this Article XAgreement, in the event there is a net decrease in LLC Minimum Gain during an LLC fiscal yearFiscal Year, the Members shall be allocated items of income and gain in accordance with Treasury Regulations Section 1.704-2(f). For purposes of this Article XAgreement, the term "LLC Minimum Gain" shall have the meaning for partnership minimum gain” gain set forth in Treasury Regulations Section 1.704-2(b)(2), and any Member’s 's share of LLC Minimum Gain shall be determined in accordance with Treasury Regulations Section 1.704-2(g)(1). This Section 10.09 9.07 is intended to comply with the minimum gain chargeback requirement of Treasury Regulations Section 1.704- 1.704-2(f) and shall be interpreted and applied in a manner consistent therewith.

Appears in 1 contract

Samples: Limited Liability Company Agreement (Burnham Pacific Properties Inc)

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LLC Minimum Gain Chargeback. Notwithstanding any other provisions of this Article X, in the event there is a net decrease in LLC Minimum Gain during an LLC fiscal yeara Fiscal Year, the Members shall be allocated items of income and gain in accordance with Treasury Regulations Section § 1.704-2(f). For purposes of this Article X, the term “LLC Minimum Gain” shall have the meaning for partnership minimum gain” gain set forth in Treasury Regulations Section § 1.704-2(b)(2), and any a Member’s share of LLC Minimum Gain shall be determined in accordance with Treasury Regulations Section § 1.704-2(g)(12(g)(l). This Section 10.09 10.07 is intended to comply with the minimum gain chargeback requirement of Treasury Regulations Section 1.704- § 1.704-2(f) and shall be interpreted and applied in a manner consistent therewith.

Appears in 1 contract

Samples: Limited Liability Company Agreement (Jack Cooper Logistics, LLC)

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