Common use of Regulatory Allocations, Qualified Clause in Contracts

Regulatory Allocations, Qualified. Income Offset and Minimum ----------------------------------------------------------- Gain Chargebacks. The provisions of this Agreement are intended to comply with ---------------- Code Section 704 and Treasury Regulations ss.ss. 1.704-1(b) and 1.704-2 and shall be interpreted and applied in x xxnner consistent with such Section and such Regulations. Notwithstanding anything to the contrary in this Agreement, the Members shall make such allocations as may be required in order to comply with Code Section 704 and Treasury Regulations ss.ss. 1.704-1(b) and 1.704-2 including any allocations necessary to xxxxxfy the requirements for (i) a "qualified income offset"; (ii) a "minimum gain chargeback"; and (iii) a chargeback of "minimum gain attributable to partner nonrecourse debt" as such terms are defined in Treasury Regulation ss.ss. 1.704-1(b) and 1.704-2.

Appears in 2 contracts

Samples: Limited Liability Company Operating Agreement (Biodelivery Sciences International Inc), Limited Liability Company Operating Agreement (Bioral Nutrient Delivery LLC)

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Regulatory Allocations, Qualified. Income Offset and Minimum ----------------------------------------------------------- Gain Chargebacks. The provisions of this Agreement are intended to comply with ---------------- Code Section 704 and Treasury Regulations ss.ss. 1.704-1(b) and 1.704-2 and shall be interpreted and applied in xx x xxnner manner consistent with such Section and such Regulations. Notwithstanding anything to the contrary in this Agreement, the Members shall make such allocations as may be required in order to comply with Code Section 704 and Treasury Regulations ss.ss. 1.704-1(b) and 1.704-2 including any allocations necessary to xxxxxfy necessarx xx satisfy the requirements for (i) a "qualified income offset"; (ii) a "minimum gain chargeback"; and (iii) a chargeback of "minimum gain attributable to partner nonrecourse debt" as such terms are defined in Treasury Regulation ss.ss. 1.704-1(b) and 1.704-2.

Appears in 1 contract

Samples: Limited Liability Company Operating Agreement (Bioral Nutrient Delivery LLC)

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Regulatory Allocations, Qualified. Income Offset and Minimum ----------------------------------------------------------- Gain Chargebacks. The provisions of this Agreement are intended to comply with ---------------- Code Section 704 and Treasury Regulations ss.ssxx.xx. 1.704-1(b) and 1.704-2 and shall be interpreted and applied in x xxnner a manner consistent with such Section and such Regulations. Notwithstanding anything to the contrary in this Agreement, the Members shall make such allocations as may be required in order to comply with Code Section 704 and Treasury Regulations ss.ssxx.xx. 1.704-1(b) and 1.704-2 including any allocations necessary to xxxxxfy satisfy the requirements for (i) a "qualified income offset"; (ii) a "minimum gain chargeback"; and (iii) a chargeback of "minimum gain attributable to partner nonrecourse debt" as such terms are defined in Treasury Regulation ss.ssxx.xx. 1.704-1(b) and 1.704-2.

Appears in 1 contract

Samples: Limited Liability Company Operating Agreement (Bioral Nutrient Delivery LLC)

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