Minimum Gain Chargeback; Qualified Income Offset. This Agreement shall be deemed to include a minimum gain chargeback as provided in Treasury Regulations Section 1.704-2(f), a partner minimum gain chargeback as provided in Treasury Regulations Section 1.704-2(i)(4) and a qualified income offset as provided in Treasury Regulations Section 1.704-1(b)(2)(ii)(d).
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Samples: Limited Liability Company Agreement (Endeavor Group Holdings, Inc.), Limited Liability Company Agreement (Endeavor Group Holdings, Inc.), Limited Liability Company Agreement (Endeavor Group Holdings, Inc.)
Minimum Gain Chargeback; Qualified Income Offset. This Agreement Notwithstanding anything to the contrary in this Agreement, Profits and Losses shall be deemed to include allocated as though this Agreement contained (and there is hereby incorporated by reference) a minimum gain chargeback as provided in Treasury Regulations provision which complies with the requirements of Section 1.704-2(f), a partner minimum gain chargeback as provided in 2 of the Treasury Regulations Section 1.704-2(i)(4) and a qualified income offset as provided in Treasury Regulations provision which complies with the regulations of Section 1.704-1(b)(2)(ii)(d)) of the Treasury Regulations.
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