Nonrecourse Deductions and Chargebacks. Notwithstanding any other provision of this Agreement to the contrary, in the event that there is a net decrease in Company Minimum Gain during a Fiscal Year, the Members shall be allocated items of income and gain (computed with the adjustments set forth in the definition of “Net Income” and “Net Loss”) in accordance with Treasury Regulations Section 1.704-2(f). The preceding sentence is intended to comply with the minimum gain chargeback requirement of Treasury Regulations Section 1.704-2(f) and shall be interpreted and applied in a manner consistent therewith.
Nonrecourse Deductions and Chargebacks. Notwithstanding any other provision of this Agreement to the contrary, nonrecourse deductions (as defined in Treasury Regulations § 1.704-2(b)(l)) shall be allocated to the Partners pro rata in accordance with their respective Percentage Interests. Notwithstanding any other provision of this Agreement to the contrary, in the event that there is a net decrease in partnership minimum gain (as that term is defined in Treasury Regulations § 1.704-2(b)(2)) during a taxable year of the Partnership, the Partners shall be allocated items of income and gain in accordance with Treasury Regulations § 1.704-2(f). The preceding sentence is intended to comply with the minimum gain chargeback requirement of Treasury Regulations Section 1.704-2(f) and shall be interpreted and applied in a manner consistent therewith.
Nonrecourse Deductions and Chargebacks. Notwithstanding any other provision of this Agreement to the contrary, all nonrecourse deductions (as defined in Treasury Regulations Section 1.704-2(b)(1)) shall be allocated to the Members pro rata in proportion to the percentages set forth in Section 7.1(a) clause third or clause fourth, whichever then applies. Notwithstanding any other provision of this Agreement to the contrary, in the event that there is a net decrease in Company Minimum Gain during a Fiscal Year, the Members shall be allocated items of income and gain in accordance with Treasury Regulations Section 1.704-2(f). The preceding sentence is intended to comply with the minimum gain chargeback requirement of Treasury Regulations Section 1.704-2(f) and shall be interpreted and applied in a manner consistent therewith.
Nonrecourse Deductions and Chargebacks. Notwithstanding any other provision of this Agreement to the contrary, nonrecourse deductions (as defined in Treasury Regulations Section 1.704-2(b)(1)) shall be allocated to the Partners in the same manner as such nonrecourse deductions would be allocated pursuant to Section 7.2 if they were Net Losses. Notwithstanding any other provision of this Agreement to the contrary, in the event that there is a net decrease in partnership minimum gain (as that term is defined in Treasury Regulations Section 1.704-2(b)(2)) with respect to the Partnership during a taxable year of the Partnership, the Partners shall be allocated items of income and gain in accordance with Treasury Regulations Section 1.704-2(f). The preceding sentence is intended to comply with the minimum gain chargeback requirement of Treasury Regulations Section 1.704-2(f) and shall be interpreted and applied in a manner consistent therewith.
Nonrecourse Deductions and Chargebacks. Notwithstanding any other provision of this LLC Agreement to the contrary, nonrecourse deductions (as defined in Regulations Section 1.704-2(b)(1)) shall be allocated to the Members pro rata in accordance with their respective Ownership Percentages. Notwithstanding any other provision of this LLC Agreement to the contrary, in the event that there is a net decrease in Company Minimum Gain during a Fiscal Year or part thereof, the Members shall be allocated items of income and gain in accordance with Regulations Section 1.704-2(f). The preceding sentence is intended to comply with the minimum gain chargeback requirements of Regulations Section 1.704-2(f) and shall be interpreted and applied in a manner consistent therewith.
