Minimum Gain Chargeback for Nonrecourse and Recourse Liabilities. The Company shall allocate income, loss and gain to comply with the minimum gain chargeback requirement contained in Treasury Regulations Section 1.704-2(f) and 1.704-2(i)(5)). Nonrecourse Liability shall be allocated in accordance with Treasury Regulations Section 1.704-2(g)(2). Recourse Liability shall be allocated to Members in accordance with Treasury Regulations Section 1.704-2(i)(4).
Appears in 33 contracts
Samples: Operating Agreement, Operating Agreement, Operating Agreement
Minimum Gain Chargeback for Nonrecourse and Recourse Liabilities. The Company shall allocate income, loss and gain to comply with the minimum gain chargeback requirement contained in Treasury Regulations Section 1.704-2(f) and 1.704-1.704- 2(i)(5)). Nonrecourse Liability shall be allocated in accordance with Treasury Regulations Section 1.704-2(g)(2). Recourse Liability shall be allocated to Members in accordance with Treasury Regulations Section 1.704-2(i)(4).
Appears in 5 contracts
Samples: Operating Agreement, Operating Agreement, LLC Operating Agreement
