Examples of Special Allocations in a sentence
For purposes of applying Section 8.1[(d) / (e)], after making the Special Allocations in Section 8.2 for the Fiscal Year or other period, if any, a Member’s Capital Account balance shall be deemed to be increased by such Member’s share of Company Minimum Gain and Member Minimum Gain determined as of the end of such Fiscal Year or other period, and such other amount a Member is deemed to be obligated to restore under Treasury Regulation §1.704-1(b)(2)(iii)(c).
For purposes of applying Section 8.1(d), after making the Special Allocations in Section 8.2 for the Fiscal Year or other period, if any, a Member’s Capital Account balance shall be deemed to be increased by such Member’s share of Company Minimum Gain and Member Minimum Gain determined as of the end of such Fiscal Year or other period, and such other amount a Member is deemed to be obligated to restore under Treasury Regulation §1.704-1(b)(2)(iii)(c).
In exercising its discretion under this paragraph (i), Managing Member shall take into account future Special Allocations under paragraphs (b) and (f) of this Exhibit that, although not yet made, are likely to offset other Special Allocations previously made under paragraph (d) and (e) of this Exhibit.
The Special Allocations are intended to comply with the requirements of the Regulations.
It is the intent of the Members that, to the extent possible, all Special Allocations shall be offset with other Special Allocations or with Special Allocations of other items of Company income, gain, loss or deduction pursuant to this Section (i).