Common use of Special Allocations for Income Tax Purposes Clause in Contracts

Special Allocations for Income Tax Purposes. Notwithstanding anything to the contrary contained in this Article 5, special allocations of Net Profits, Net Losses or specific items of income, gain, loss or deduction shall be required for any Fiscal Year as follows: (i) Company Minimum Gain Chargeback and Member Minimum Gain Chargeback. The Company shall allocate items of income and gain among the Members at such times and in such amounts as necessary to satisfy the minimum gain chargeback requirements of Treasury Regulation Sections 1.704-2(f) and 1 .704-2(i)(4).