Minimum Gain Chargebacks. Notwithstanding Section 4.1, Profits (including any gross income or gains) shall be allocated and shared between or among the Members so as to comply with the “minimum gain chargeback” provisions in Treas. Reg. § 1.704–2 (applicable to partnership non-recourse debt or partner non-recourse debt, as the case may be).
Appears in 3 contracts
Samples: Operating Agreement, Operating Agreement, Operating Agreement
