Common use of Regulatory and Special Allocations Clause in Contracts

Regulatory and Special Allocations. Notwithstanding the ---------------------------------- provisions of Section 5.3: ----------- (a) If there is a net decrease in Company Minimum Gain during any Taxable Year, each Member shall be specially allocated items of taxable income or gain for such Taxable Year (and, if necessary, subsequent Taxable Years) in an amount equal to such Member's share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulation Section 1.704- 2(g). The items to be so allocated shall be determined in accordance with Treasury Regulation Sections 1.704-2(f)(6) and 1.704-2(j)

Regulatory and Special Allocations. Notwithstanding the ---------------------------------- provisions of Section 5.3: -----------: (a) COMPANY MINIMUM GAIN. If there is a net decrease in Company Minimum Gain during any Taxable Year, each Member and Economic Owner shall be specially allocated items of taxable income or gain Profits for such Taxable Year (and, if necessary, subsequent Taxable Years) in an amount equal to such Member's and Economic Owner's share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulation Section 1.704- 1.704-2(g). The items to be so allocated shall be determined in accordance with Treasury Regulation Sections 1.704-2(f)(6) and 1.704-2(j)

Regulatory and Special Allocations. Notwithstanding the ---------------------------------- provisions of Section 5.38.1: ----------- (a) If there is a net decrease in Company Minimum Gain (determined according to Treasury Regulation Section 1.704-2(d)(1)) during any Taxable Year, each Member shall be specially allocated items of taxable income or gain Profits for such Taxable Year (and, if necessary, subsequent Taxable Years) in an amount equal to such Member's share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulation Section 1.704- 1.704-2(g). The items to be so allocated shall be determined in accordance with Treasury Regulation Sections Section 1.704-2(f)(6) and 1.704-2(j)

Regulatory and Special Allocations. Notwithstanding the ---------------------------------- provisions of Section 5.3: ----------- (aA) COMPANY MINIMUM GAIN CHARGEBACK. If there is a net decrease in Company Minimum Gain during any Taxable Year, each Member shall be specially allocated items of taxable income or gain for such Taxable Year (and, if necessary, subsequent Taxable Years) in an amount equal to such Member's share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulation Section 1.704- 1.704-2(g). The items to be so allocated shall be determined in accordance with Treasury Regulation Sections 1.704-2(f)(6) and 1.704-2(j)