Common use of Minimum Gain Chargeback—Company Nonrecourse Liabilities Clause in Contracts

Minimum Gain Chargeback—Company Nonrecourse Liabilities. If there is a net decrease in Company Minimum Gain during any Fiscal Year, certain items of income and gain shall be allocated (on a gross basis) to the Members in the amounts and manner described in Regulations Section 1.704-2(f) and (j)(2)(i) and (ii), subject to the exemptions set forth in Regulations Section 1.704-2(f)(2), (3), (4), and (5). This Section 5.2(a) is intended to comply with the minimum gain chargeback requirement (set forth in Regulations Section 1.704-2(f)) relating to Company nonrecourse liabilities (as defined in Regulations Section 1.704-2(b)(3)) and shall be so interpreted.

Appears in 3 contracts

Samples: Limited Liability Company Agreement (Dean Foods Co), Limited Liability Company Agreement (Consolidated Container Co LLC), Limited Liability Company Agreement (Consolidated Container Co LLC)

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Minimum Gain Chargeback—Company Nonrecourse Liabilities. If there is a net decrease in Company Minimum Gain during any Fiscal YearCompany taxable year, certain items of income and gain shall be allocated (on a gross basis) to the Members in the amounts and manner described in Regulations Section 1.704-2(f) and (j)(2)(i) and (ii), subject to of the exemptions set forth in Regulations Section 1.704-2(f)(2), (3), (4), and (5)Treasury Regulations. This Section 5.2(a5.3(a)(iii) is intended to comply with the minimum gain chargeback requirement (set forth in Regulations Section 1.704-2(f)) of the Treasury Regulations) relating to Company nonrecourse liabilities (as defined in Regulations Section 1.704-2(b)(3)) of the Treasury Regulations) and shall be so interpreted.

Appears in 1 contract

Samples: Company Agreement (Vernafund CF LLC)

Minimum Gain Chargeback—Company Nonrecourse Liabilities. If there is a net decrease in Company Partnership Minimum Gain during any Fiscal Year, certain items of income and gain shall will be allocated (on a gross basis) to the Members in accordance with the amounts and manner rules described in Tax Regulations Section 1.704-2(f) and (j)(2)(i) and (iiiii), subject to the exemptions set forth in Tax Regulations Section 1.704-2(f)(2), (3), (4), ) and (5). This Section 5.2(a5.2fa) is intended to comply with the minimum gain chargeback requirement (set forth in Tax Regulations Section 1.704-2(f)) relating to Company nonrecourse liabilities (as defined in Tax Regulations Section 1.704-2(b)(3)) and shall will be so interpreted.

Appears in 1 contract

Samples: Operating Agreement (Perot Systems Corp)

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Minimum Gain Chargeback—Company Nonrecourse Liabilities. If there is a net decrease in Company Minimum Gain during any Fiscal Year, certain items of income and gain shall will be allocated (on a gross basis) to the Members in accordance with the amounts and manner rules described in Regulations Section sections 1.704-2(f) and ), (j)(2)(i) and (iij)(2)(iii), subject to the exemptions set forth in Regulations Section 1.704section l.704-2(f)(2), (3), (4), ) and (5). This Section 5.2(a) 8.3.1 is intended to comply with the minimum gain chargeback chargeback” requirement (set forth in Regulations Section section 1.704-2(f)) relating to Company partnership nonrecourse liabilities (as defined in Regulations Section 1.704section l.704-2(b)(3)) and shall will be so interpreted.

Appears in 1 contract

Samples: Operating Agreement (Tri-Isthmus Group, Inc.)

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