Chargeback of Minimum Gain Attributable to Member Nonrecourse Debt. Except as provided in Treasury Regulations Section 1.704-2(i)(5), if there is a net decrease in Minimum Gain Attributable to Member Nonrecourse Debt during any Company taxable period, any Member with a share of Minimum Gain Attributable to Company Nonrecourse Debt at the beginning of such taxable period shall be allocated items of Company income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulations Section 1.704-2(i)(4) or any successor provisions.
Appears in 6 contracts
Samples: Operating Agreement (Pebblebrook Hotel Trust), Operating Agreement (Hersha Hospitality Trust), Operating Agreement (Pebblebrook Hotel Trust)
