Common use of Company Minimum Gain Chargeback Clause in Contracts

Company Minimum Gain Chargeback. Notwithstanding any other provision of this Section 5.1, if there is a net decrease in Company Minimum Gain during any Company taxable period, each Member 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 Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 5.1(b), each Member’s Adjusted Capital Account balance shall be determined, and the allocation of income and gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 5.1(b) with respect to such taxable period (other than an allocation pursuant to Section 5.1(b)(iii) and Section 5.1(b)(vi)). This Section 5.1(b)(i) is intended to comply with the Company Minimum Gain chargeback requirement in Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding any other provision of this Section 5.1, if there is a net decrease in Company Minimum Gain during any Company taxable period, each Member shall be allocated items of Company income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in determined according to Treasury Regulations Sections 1.704-2(f)(6), 1.704-2(g)(22(f) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 5.1(b), each Member’s Adjusted Capital Account balance shall be determined, and the allocation of income and gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 5.1(b) with respect to such taxable period (other than an allocation pursuant to Section 5.1(b)(iii) and Section 5.1(b)(vi)). This Section 5.1(b)(i) is intended to comply with the Company Minimum Gain chargeback requirement in Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding any other provision of this Section 5.14.1, if there is a net decrease in Company Minimum Gain during any Company taxable period, each Member 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 Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 5.1(b4.1(d), each Member’s Adjusted Capital Account balance shall be determined, and the allocation of income and gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 5.1(b4.1(d) with respect to such taxable period (other than an allocation pursuant to Section 5.1(b)(iiiSections 4.1(d)(iii) and Section 5.1(b)(vi4.1(d)(vi)). This Section 5.1(b)(i4.1(d)(i) is intended to comply with the Company Minimum Gain chargeback requirement in Treasury Regulations Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding any other provision of this Section 5.16.1, if there is a net decrease in Company Minimum Gain during any Company taxable period, each Member 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 Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 5.1(b6.1(d), each Member’s 's Adjusted Capital Account balance shall be determined, and the allocation of income and or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 5.1(b6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 5.1(b)(iii6.1(d)(vi) and Section 5.1(b)(vi6.1(d)(vii)). This Section 5.1(b)(i6.1(d)(i) is intended to comply with the Company Minimum Gain chargeback requirement in Treasury Regulations Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding any other provision of this Section 5.16.1, if there is a net decrease in Company Minimum Gain during any Company taxable period, each Member 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 Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 5.1(b6.1(d), each Member’s Adjusted Capital Account balance shall be determined, and the allocation of income and or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 5.1(b6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 5.1(b)(iiiSections 6.1(d)(vi) and Section 5.1(b)(vi6.1(d)(vii)). This Section 5.1(b)(i6.1(d)(i) is intended to comply with the Company Minimum Gain chargeback requirement in Treasury Regulations Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding any other provision of this Section 5.16.1, if there is a net decrease in Company Minimum Gain during any Company taxable period, each Member 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 Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 5.1(b6.1(d), each Member’s Adjusted Capital Account balance shall be determined, and the allocation of income and or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 5.1(b6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 5.1(b)(iii6.1(d)(vi) and Section 5.1(b)(vi6.1(d)(vii)). This Section 5.1(b)(i6.1(d)(i) is intended to comply with the Company Minimum Gain chargeback requirement in Treasury Regulations Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding any other provision of this Section 5.14.1, if there is a net decrease in Company Minimum Gain during any Company taxable period, each Member 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 Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 5.1(b4.1(c), each Member’s Adjusted Capital Account balance shall be determined, and the allocation of income and gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 5.1(b4.1(c) with respect to such taxable period (other than an allocation pursuant to Section 5.1(b)(iiiSections 4.1(c)(iii) and Section 5.1(b)(vi4.1(c)(vi)). This Section 5.1(b)(i4.1(c)(i) is intended to comply with the Company Minimum Gain chargeback requirement in Treasury Regulations Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding any other provision of this Section 5.1, if there is a net decrease in Company Minimum Gain during any Company taxable period, each Member 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 Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 5.1(b5.1(e), each Member’s Adjusted Capital Account balance shall be determined, and the allocation of income and gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 5.1(b5.1(e) with respect to such taxable period (other than an allocation pursuant to Section 5.1(b)(iii5.1(e)(iii) and Section 5.1(b)(vi5.1(e)(vi)). This Section 5.1(b)(i5.1(e)(i) is intended to comply with the Company Minimum Gain chargeback requirement in Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding any other provision of this Section 5.1, if there is a net decrease in Company Minimum Gain during any Company taxable period, each Member 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 Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 5.1(b), each Member’s Adjusted Capital Account balance shall be determined, and the allocation of income and gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 5.1(b) with respect to such taxable period (other than an allocation pursuant to Section 5.1(b)(iii) and Section 5.1(b)(vi)). This Section 5.1(b)(i5.l(b)(i) is intended to comply with the Company Minimum Gain chargeback requirement in Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding any other provision of this Section 5.14.2, if there is a net decrease in Company Minimum Gain during any Company taxable period, each Member Shareholder 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 Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 5.1(b4.2(b), each MemberShareholder’s Adjusted Capital Account balance shall be determined, and the allocation of income and gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 5.1(b4.2(b) with respect to such taxable period (other than an allocation pursuant to Section 5.1(b)(iiiSections 4.2(b)(iii) and Section 5.1(b)(vi4.2(b)(vi)). This Section 5.1(b)(i4.2(b)(i) is intended to comply with the Company Minimum Gain chargeback requirement in Treasury Regulations Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding any other provision of this Section 5.16.1, if there is a net decrease in Company Minimum Gain during any Company taxable period, each Member 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 Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 5.1(b6.1(d), each Member’s Adjusted Capital Account balance shall be determined, and the allocation of income and income, gain or Simulated Gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 5.1(b6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 5.1(b)(iiiSections 6.1(d)(v) and Section 5.1(b)(vi6.1(d)(vi)). This Section 5.1(b)(i6.1(d)(i) is intended to comply with the Company Minimum Gain chargeback requirement in Treasury Regulations Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding any the other provision provisions of this Section 5.15.02, except as provided in Treasury Regulation Section 1.704-2(f), if there is a net decrease in Company Minimum Gain during any Company taxable period, each Member shall be allocated items of Company income and gain for such period (and, if necessary, necessary subsequent periods) in the manner and in the amounts provided in Treasury Regulations Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and ), 1.704-2(j)(2)(i), ) or any successor provisionprovisions. This Section 5.02(c)(i) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith. For purposes of this Section 5.1(b5.02(c)(i), each Member’s Adjusted Capital Account balance shall be determined, and the allocation of income and or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 5.1(b) with respect to such taxable period (other than an allocation pursuant to Section 5.1(b)(iii) and Section 5.1(b)(vi)). This Section 5.1(b)(i) is intended to comply with the Company Minimum Gain chargeback requirement in Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith5.02.

Company Minimum Gain Chargeback. Notwithstanding any the other provision provisions of this Section 5.15.03, except as provided in Treasury Regulation Section 1.704-2(f), if there is a net decrease in Company Minimum Gain during any Company taxable period, each Member shall be allocated items of Company income and gain for such period (and, if necessary, necessary subsequent periods) in the manner and in the amounts provided in Treasury Regulations Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and ), 1.704-2(j)(2)(i), ) or any successor provisionprovisions. This Section 5.03(c)(i) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith. For purposes of this Section 5.1(b5.03(c)(i), each Member’s Adjusted Capital Account balance shall be determined, and the allocation of income and or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 5.1(b) with respect to such taxable period (other than an allocation pursuant to Section 5.1(b)(iii) and Section 5.1(b)(vi)). This Section 5.1(b)(i) is intended to comply with the Company Minimum Gain chargeback requirement in Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith5.03.

Company Minimum Gain Chargeback. Notwithstanding any other provision of this Section 5.16.1, if there is a net decrease in Company Minimum Gain during any Company taxable period, each Member 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 Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 5.1(b6.1(d), each Member’s Adjusted Capital Account balance shall be determined, and the allocation of income and gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 5.1(b6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 5.1(b)(iii6.1(d)(vi) and Section 5.1(b)(vi6.1(d)(vii)). This Section 5.1(b)(i6.1(d)(i) is intended to comply with the Company Minimum Gain chargeback requirement in Treasury Regulations Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding any other provision of this Section 5.1, if there is a net decrease in Company Minimum Gain during any Company taxable period, each Member 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 Regulation Sections 1.704-2(f)(61.704(f)(6), 1.704-2(g)(21.704(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 5.1(b5.1(d), each Member’s 's Adjusted Capital Account balance shall be determined, and the allocation of income and or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 5.1(b5.1(d) with respect to such taxable period (other than an allocation pursuant to Section 5.1(b)(iiiSections 5.1(d)(vi) and Section 5.1(b)(vi5.1(d)(vii)). This Section 5.1(b)(i5.1(d)(i) is intended to comply with the Company Minimum Gain chargeback requirement in Treasury Regulations Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding any the other provision provisions of this Section 5.1, if there is a net decrease in Company Minimum Gain during any Company taxable period, each Member shall be allocated items of Company income and gain for such taxable period (and, if necessary, subsequent taxable periods) in the manner and amounts provided in Treasury Regulations Sections Regulation sections 1.704-2(f)(6), 1.704-2(g)(2) and (g)(2) and section 1.704-2(j)(2)(i), or any successor provisionprovisions. For purposes of this Section 5.1(b5.1(c), each Member’s Adjusted Capital Account balance shall be determined, and the allocation of income and or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 5.1(b5.1(c) with respect to such taxable period (other than an allocation pursuant to Section 5.1(b)(iii5.1(c)(v) and Section 5.1(b)(vi)5.1(c)(vi). This Section 5.1(b)(i5.1(c)(i) is intended to comply with the Company Minimum Gain chargeback requirement in Treasury Regulations Section Regulation section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Notwithstanding any other provision of this Section 5.14.1, if there is a net decrease in Company Minimum Gain during any Company taxable period, each Member 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 Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 5.1(b4.1(c), each Member’s 's Adjusted Capital Account balance shall be determined, and the allocation of income and gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 5.1(b4.1(c) with respect to such taxable period (other than an allocation pursuant to Section 5.1(b)(iiiSections 4.1(c)(iii) and Section 5.1(b)(vi4.1(c)(vi)). This Section 5.1(b)(i4.1(c)(i) is intended to comply with the Company Minimum Gain chargeback requirement in Treasury Regulations Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.