Minimum Gain. Notwithstanding any other provision of this Article 8, if there is a net decrease in Company non-recourse debt or Member non-recourse debt, minimum gain shall be determined in accordance with the principles of Treasury Regulations Sections 1.704-2 and 1.704-2, and each Member shall be specially allocated items of Company income and gain for such year (and, if necessary, subsequent years) in an amount equal to the Member’s respective share of such net decrease during such year, determined pursuant to Treasury Regulations Sections 1.704-2. The items to be so allocated shall be determined in accordance with Treasury Regulations Section 1.704-2.
Appears in 6 contracts
Samples: Operating Agreement (Pedevco Corp), Operating Agreement (Pedevco Corp), Operating Agreement (Pedevco Corp)
