Common use of Waiver of Application of Minimum Gain Chargeback Clause in Contracts

Waiver of Application of Minimum Gain Chargeback. The Managing Member shall request from the Commissioner of the Internal Revenue Service a waiver, pursuant to Treasury Regulation Section 1.704 -2(f)(4), of the minimum gain chargeback requirements of Treasury Regulation Section 1.704 -2(f) if the application of such minimum gain chargeback requirement would cause a permanent distortion of the economic arrangement of the Members, as reflected in Section 8.1.

Waiver of Application of Minimum Gain Chargeback. The Managing Member shall request from the Commissioner of the Internal Revenue Service a waiver, pursuant to Treasury Regulation Section 1.704 -2(f)(41.704-2(f)(4), of the minimum gain chargeback requirements of Treasury Regulation Section 1.704 -2(f1.704-2(f) if the application of such minimum gain chargeback requirement would cause a permanent distortion of the economic arrangement of the Members, as reflected in Section 8.1.

Waiver of Application of Minimum Gain Chargeback. The Managing Member shall Board of Managers may request from the Commissioner of the Internal Revenue Service a waiver, pursuant to Treasury Regulation Section 1.704 -2(f)(41.704-2(f)(4), of the minimum gain chargeback requirements of Treasury Regulation Section 1.704 -2(f1.704-2(f) if the application of such minimum gain chargeback requirement would cause a permanent distortion of the economic arrangement of the Members, as reflected in Section 8.1Unitholders.