Minimum Gain Chargeback; Qualified Income Offset. Items of Company income and gain shall be allocated to the Owners in an amount sufficient to satisfy the “minimum gain chargeback” requirements of Sections 1.704-2(f) and 1.704-2(i)(4) of the Regulations and the “qualified income offset” requirement of Section 1.704-1(b)(2)(ii)(g)(3) of the Regulations.
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Samples: Operating Agreement (Safe & Green Development Corp), Operating Agreement (Safe & Green Development Corp), Operating Agreement (Sg Blocks, Inc.)
Minimum Gain Chargeback; Qualified Income Offset. Items of Company income and gain shall be allocated for any Allocation Period to the Owners extent, and in an amount sufficient to satisfy the “minimum gain chargeback” requirements of Sections Treasury Regulation Section 1.704-2(f) and 1.704-2(i)(4(i)(4) of the Regulations and the “qualified income offset” requirement of Treasury Regulation Section 1.704-1(b)(2)(ii)(g)(3) of the Regulations1(b)(2)(ii)(d)(3).
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Minimum Gain Chargeback; Qualified Income Offset. Items of Company income and gain shall be allocated for any Fiscal Year to the Owners extent, and in an amount sufficient to satisfy the “minimum gain chargeback” requirements of Sections Section 1.704-2(f) and 1.704-2(i)(4(i)(4) of the Regulations and the “qualified income offset” requirement of Section 1.704-1(b)(2)(ii)(g)(3l(b)(2)(ii)(d)(3) of the Regulations.
Appears in 1 contract
Samples: Operating Agreement (iPCS, INC)
Minimum Gain Chargeback; Qualified Income Offset. Items of Company income and gain shall be allocated to the Owners any Fiscal Year in an amount sufficient to satisfy the “minimum gain chargeback” requirements of Sections 1.704-2(f) and 1.704-2(i)(4(i)(4) of the Regulations and the “qualified income offset” requirement of Section 1.704-1(b)(2)(ii)(g)(31(b)(2)(ii)(d)(3) of the Regulations.
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