Qualified Income Offset, Minimum Gain Chargeback. Notwithstanding anything to the contrary in this Agreement, there is hereby incorporated a qualified income offset provision which complies with Treasury Regulation Section 1.704-1(b)(2)(ii)(d) and minimum gain chargeback and partner minimum gain chargeback provisions which comply with the requirements of Treasury Regulation Section 1.704-2 and such provisions shall apply to the allocation of Profits and Losses.
Appears in 7 contracts
Samples: Limited Liability Company Agreement (Ashland Inc), Limited Liability Company Agreement (Marathon Oil Corp), Limited Liability Company Agreement (Marathon Oil Corp)
