LLC Minimum Gain definition

LLC Minimum Gain means the amount determined by computing with respect to each nonrecourse liability of the LLC, the amount of gain (of whatever character), if any, that would be realized by the LLC if it disposed (in a taxable transaction) of the Property subject to such liability in full satisfaction thereof, and by then aggregating the amounts so computed as set forth in Regulations Section 1.704-2(d).
Sample 1Sample 2Sample 3
LLC Minimum Gain has the meaning of “partnership minimum gain” set forth in Treasury Regulations § 1.704-2(d), and is generally the aggregate gain the LLC would realize if it disposed of its property subject to Nonrecourse Liabilities in full satisfaction of each such liability and for no other consideration, with such other modifications as provided in Treasury Regulations § 1.704-2(d). In the case of Nonrecourse Liabilities for which the creditor’s recourse is not limited to particular assets of the LLC, until such time as there is regulatory guidance on the determination of minimum gain with respect to such liabilities, all such liabilities of the LLC shall be treated as a single liability and allocated to the LLC’s assets using any reasonable basis selected by the Board.
Sample 1Sample 2Sample 3
LLC Minimum Gain has the meaning given to the term “partnership minimum gain” in Regulations Sections 1.704-2(b)(2) and 1.704-2(d).
Sample 1Sample 2Sample 3

Examples of LLC Minimum Gain in a sentence

  • If there is a net decrease in LLC Minimum Gain for a Fiscal Year, each Member shall be allocated items of LLC income and gain for such year (and, if necessary, subsequent years) in an amount equal to such Member’s share of such net decrease in LLC Minimum Gain, determined in accordance with Treasury Regulations § 1.704-2(g)(2) and the definition of LLC Minimum Gain set forth above.

  • If, during a taxable year, the LLC makes a distribution to any Member that is allocable to the proceeds of any nonrecourse liability of the LLC that is allocable to an increase in LLC Minimum Gain pursuant to Treasury Regulations Section 1.704-2(h), then the LLC shall elect, to the extent permitted by Treasury Regulations Section 1.704-2(h)(3), to treat such distribution as a distribution that is not allocable to an increase in LLC Minimum Gain.

  • If there is a net decrease in LLC Minimum Gain during a fiscal year, each Member will be allocated, before any other allocation under this Article IV, items of income and gain for such fiscal year (and, if necessary, subsequent years) in proportion to and to the extent of an amount equal to such Member's share of the net decrease in LLC Minimum Gain determined in accordance with Regulations Section 1.704-2(g)(2).

  • The District obtained a $2,000,000 Royal Bank of Canada multi-draw term loan in order to fund the construction costs.

  • Notwithstanding any other provisions of this Article X, in the event there is a net decrease in LLC Minimum Gain during an LLC fiscal year, the Members shall be allocated items of income and gain in accordance with Treasury Regulations Section 1.704-2(f).


More Definitions of LLC Minimum Gain

LLC Minimum Gain shall have the meaning for “partnership minimum gain” set forth in Treasury Regulations Section 1.704-2(b)(2), and any Member’s share of LLC Minimum Gain shall be determined in accordance with Treasury Regulations Section 1.704-2(g)(1). This Section 10.09 is intended to comply with the minimum gain chargeback requirement of Treasury Regulations Section 1.704- 2(f) and shall be interpreted and applied in a manner consistent therewith.
Sample 1Sample 2Sample 3
LLC Minimum Gain has the meaning set forth in Sections 1.704-2(b)(2) and 1.704-2(d) of the Treasury Regulations.
Sample 1Sample 2Sample 3
LLC Minimum Gain means LLC minimum gain computed in accordance with the principles of ss. 1.7042(d) of the Treasury Regulations.
Sample 1Sample 2Sample 3
LLC Minimum Gain has the meaning for partnership minimum gain set forth in Regulations Section 1.704-2(b)(2), and the amount of LLC Minimum Gain, as well as any net increase or decrease in an LLC Minimum Gain, for an LLC taxable year shall be determined in accordance with the rules of Regulations Section 1.704-2(d).
Sample 1Sample 2
LLC Minimum Gain means that amount determined in accordance with the principles of Regulations Sec. 1.704-2(d).
Sample 1
LLC Minimum Gain has the meaning set forth in Regulations Sections 1.704-2(d) and 1.704-2(d). For purposes of the Regulations Section 1.704, Company shall mean partnership where the context of such regulation require.
Sample 1
LLC Minimum Gain shall have the meaning set forth in Section 9.07.
Sample 1