Qualified Income Offset Allocation. In the event any Member unexpectedly receives any adjustments, allocations or Distributions described in Regulation Sections 1.704-1(b)(2)(ii)(d)(4), (5), or (6) which would cause such Member to have an Adjusted Capital Account Deficit, items of Company income and gain shall be specially allocated to such Member in an amount and manner sufficient to eliminate, to the extent required by the Regulations, such Adjusted Capital Account Deficit as quickly as possible. This Section 9.03(c) is intended to constitute a “qualified income offset” in satisfaction of the alternate test for economic effect set forth in Regulation Section 1.704-1(b)(2)(ii)(d)(3) and is to be interpreted to the extent possible, to comply with the requirements of such Regulation as it may be amended or supplemented from time to time.
Appears in 7 contracts
Samples: Operating Agreement, Operating Agreement, Operating Agreement
