Common use of Member Nonrecourse Debt Minimum Gain Chargeback Clause in Contracts

Member Nonrecourse Debt Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation Section 1.704-2(i)(4), if there is a net decrease in Member Minimum Gain attributable to a “Member Nonrecourse Debt” (as those terms are defined in Treasury Regulation Section 1.704-2(b)(4)) during any Taxable Year, each Member that has a share of such Member Minimum Gain shall be specially allocated items of taxable income or gain for such Taxable Year (and, if necessary, subsequent Taxable Years) in an amount equal to that Member’s share of the net decrease in Member Minimum Gain. Items to be allocated pursuant to this paragraph shall be determined in accordance with Treasury Regulation Sections 1.704-2(i)(4) and 1.704-2(j)(2). This Section 5.6(B) is intended to comply with the minimum gain chargeback requirements in Treasury Regulation Section 1.704-2(i)(4) and shall be interpreted consistently therewith.

Member Nonrecourse Debt Minimum Gain Chargeback. Except as otherwise provided Subject to the exceptions contained in Treasury Regulation Section 1.704-2(i)(4), if there is a net decrease in Member Nonrecourse Debt Minimum Gain attributable to during a “Fiscal Year, any Member with a share of such Member Nonrecourse Debt” Debt Minimum Gain (as those terms are defined determined in accordance with Treasury Regulation Section 1.704-2(b)(42(i)(5)) during any Taxable Year, each Member that has a share as of the beginning of such Member Minimum Gain year shall be specially allocated items of taxable income or and gain for such Taxable Year year (and, if necessary, for subsequent Taxable Yearsyears) in an amount equal to that such Member’s share of the net decrease in Member Nonrecourse Debt Minimum Gain. Items to be allocated pursuant to this paragraph Gain (which share of such net decrease shall be determined in accordance with under Treasury Regulation Sections 1.704-2(i)(4) and 1.704-2(j)(2)). This Section 5.6(B) It is intended to comply with the that this Section 1.4(b) shall constitute a “partner nonrecourse debt minimum gain chargeback requirements in chargeback” as provided by Treasury Regulation Section 1.704-2(i)(4) and shall be interpreted consistently therewith.

Member Nonrecourse Debt Minimum Gain Chargeback. Member Nonrecourse Deductions shall be allocated in the manner required by Treasury Regulation Section 1.704-2(i). Except as otherwise provided in Treasury Regulation Section 1.704-2(i)(4), if there is a net decrease in Member Minimum Gain attributable to a “Member Nonrecourse Debt” (as those terms are defined in Treasury Regulation Section 1.704-2(b)(4)) during any Taxable Year, each Member that has a share of such Member Minimum Gain shall be specially allocated items of taxable income or gain for such Taxable Year (and, if necessary, subsequent Taxable Years) in an amount equal to that Member’s share of the net decrease in Member Minimum Gain. Items to be allocated pursuant to this paragraph shall be determined in accordance with Treasury Regulation Sections 1.704-2(i)(4) and 1.704-2(j)(2). This Section 5.6(B) paragraph is intended to comply with the minimum gain chargeback requirements in Treasury Regulation Section 1.704-2(i)(4) and shall be interpreted consistently therewith.

Member Nonrecourse Debt Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation Regulations Section 1.704-2(i)(4), notwithstanding any other provision of this Section 5, if there is a net decrease in Member Nonrecourse Debt Minimum Gain attributable to a “Member Nonrecourse Debt” (as those terms are defined in Treasury Regulation Section 1.704-2(b)(4)) during any Taxable YearGain, each Member that who has a share of such Member Nonrecourse Debt Minimum Gain shall be specially allocated items of taxable Net Profits and other items of Company income or and gain for such Taxable Year fiscal year (and, if necessary, subsequent Taxable Yearsfiscal years) in an amount equal to that the portion of such Member’s share of the net decrease in Member Nonrecourse Debt Minimum Gain. Items The items to be so allocated pursuant to this paragraph shall be determined in accordance with Treasury Regulation Regulations Sections 1.704-2(i)(4) and 1.704-2(j)(2). This Section 5.6(B) 5.2 is intended to comply with the “minimum gain chargeback requirements in chargeback” requirement of Treasury Regulation Section 1.704-2(i)(4) and shall be interpreted consistently therewithwith such Regulation.

Member Nonrecourse Debt Minimum Gain Chargeback. Except as otherwise provided Subject to the exceptions contained in Treasury Regulation Regulations Section 1.704-2(i)(4), if there is a net decrease in Member Nonrecourse Debt Minimum Gain attributable to during a “Member Nonrecourse Debt” (as those terms are defined in Treasury Regulation Section 1.704-2(b)(4)) during any Taxable Fiscal Year, each any Member that has with a share of such Member Nonrecourse Debt Minimum Gain (determined in accordance with Treasury Regulations Section 1.704-2(i)(5)) as of the beginning of such Fiscal Year shall be specially allocated items of taxable income or and gain for such Taxable Fiscal Year (and, if necessary, for subsequent Taxable Yearsyears) in an amount equal to that such Member’s share of the net decrease in Member Nonrecourse Debt Minimum Gain. Items to be allocated pursuant to this paragraph Gain (which share of such net decrease shall be determined in accordance with under Treasury Regulation Regulations Sections 1.704-2(i)(4) and 1.704-2(j)(22(g)(2)). This Section 5.6(B) It is intended to comply with the that this Section 5.6(c)(ii) shall constitute a “partner nonrecourse debt minimum gain chargeback requirements in chargeback” as provided by Treasury Regulation Regulations Section 1.704-2(i)(4) and shall be interpreted consistently therewith.

Member Nonrecourse Debt Minimum Gain Chargeback. Member Nonrecourse Deductions shall be allocated in the manner required by Treasury Regulation Section 1.704-2(i). Except as otherwise provided in Treasury Regulation Section 1.704-2(i)(4), if there is a net decrease in Member Nonrecourse Debt Minimum Gain attributable to a “Member Nonrecourse Debt” (as those terms are defined in Treasury Regulation Section 1.704-2(b)(4)) during any Taxable Yeartaxable year, each Member that has a share of such Member Nonrecourse Debt Minimum Gain shall be specially allocated items of taxable income or gain for such Taxable Year taxable year (and, if necessary, subsequent Taxable Yearstaxable years) in an amount equal to that Member’s share of the net decrease in Member Nonrecourse Debt Minimum Gain. Items to be allocated pursuant to this paragraph Section 9.2.2 shall be determined in accordance with Treasury Regulation Sections 1.704-2(i)(4) and 1.704-2(j)(2). This Section 5.6(B) 9.2.2 is intended to comply with the minimum gain chargeback requirements in Treasury Regulation Section 1.704-2(i)(4) and shall be interpreted consistently therewith.

Member Nonrecourse Debt Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation Section 1.704-2(i)(4), if there is a net decrease in Member Minimum Gain attributable to a “Member Nonrecourse Debt” (as those terms are defined in Treasury Regulation Section 1.704-2(b)(4)) during any Taxable Year, each Member that has a share of such Member Minimum Gain shall be specially allocated items of taxable income or gain for such Taxable Year (and, if necessary, subsequent Taxable Years) in an amount equal to that Member’s share of the net decrease in Member Minimum Gain. Items to be allocated pursuant to this paragraph shall be determined in accordance with Treasury Regulation Sections 1.704-2(i)(4) and 1.704-2(j)(2). This Section 5.6(B) paragraph is intended to comply with the partner nonrecourse debt minimum gain chargeback requirements in Treasury Regulation Section 1.704-2(i)(4) and shall be interpreted consistently therewith.

Member Nonrecourse Debt Minimum Gain Chargeback. Member Nonrecourse Deductions shall be allocated in the manner required by Treasury Regulation Section 1.704-2(i). Except as otherwise provided in Treasury Regulation Section 1.704-2(i)(4), if there is a net decrease in Member Minimum Gain attributable to a “Member Nonrecourse Debt” (as those terms are defined in Treasury Regulation Section 1.704-2(b)(4)) during any Taxable Year, each Member that has a share of such Member Minimum Gain shall be specially allocated items of taxable income or gain for such Taxable Year (and, if necessary, subsequent Taxable Years) in an amount equal to that Member’s share of the net decrease in Member Minimum Gain. Items to be allocated pursuant to this paragraph shall be determined in accordance with Treasury Regulation Sections 1.704-2(i)(4) ) and 1.7041. 704-2(j)(2). This Section 5.6(B) paragraph is intended to comply with the minimum gain chargeback requirements in Treasury Regulation Section 1.704-2(i)(4) and shall be interpreted consistently therewith.