LIMITED LIABILITY COMPANY AGREEMENT OF THREE LIONS ENTERTAINMENT, LLC A DELAWARE LIMITED LIABILITY COMPANYEmployment Agreement • August 7th, 2013 • Simon Worldwide Inc • Apparel & other finishd prods of fabrics & similar matl • New York
with Treasury Regulations Section 1.704-2(i)(4). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Sections 1.704-2(i)(4) and 1.704-2(j)(2). This Paragraph 1.4(b) is intended to comply with the minimum gain chargeback requirement in Treasury Regulations Section 1.704-2(i)(4) and shall be interpreted consistently therewith.
