Common use of Company Minimum Gain Chargeback Clause in Contracts

Company Minimum Gain Chargeback. In the event there is a net decrease in Company Minimum Gain during a fiscal year, the Members shall be allocated items of income and gain in accordance with Treasury Regulations Section 1.704-2(f). For purposes of this Agreement, the term “Company 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 Company Minimum Gain shall be determined in accordance with Treasury Regulations Section 1.704-2(g)(1). This Section 8.3(a) 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.

Appears in 14 contracts

Samples: Limited Liability Company Agreement (Global Growth Trust, Inc.), Limited Liability Company Agreement (Global Growth Trust, Inc.), Limited Liability Company Agreement (CNL Growth Properties, Inc.)

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Company Minimum Gain Chargeback. In the event If there is a net decrease in Company Minimum Gain during a fiscal yearany Taxable Year, the Members each Member shall be specially allocated items of taxable income and or gain for such Taxable Year (and, if necessary, subsequent Taxable Years) in an amount equal to such Member’s share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulations Regulation Section 1.704-2(f2(g). For purposes of this Agreement, the term “Company 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 Company Minimum Gain The items to be so allocated shall be determined in accordance with Treasury Regulations Section Regulation Sections 1.704-2(g)(12(f)(6) and 1.704-2(j)(2). This Section 8.3(a) paragraph is intended to comply with the minimum gain chargeback requirement of in Treasury Regulations Regulation Section 1.704-2(f) and shall be interpreted and applied in a manner consistent consistently therewith.

Appears in 3 contracts

Samples: Limited Liability Company Agreement (Centerpoint Properties Trust), Limited Liability Company Agreement (Phillips Edison Grocery Center Reit Ii, Inc.), Limited Liability Company Agreement (Centerpoint Properties Trust)

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Company Minimum Gain Chargeback. In the event there is a net decrease in Company Minimum Gain during a fiscal yeartaxable year (or other period for which the Treasury Regulations requires an allocation to be made), the Members shall be allocated items of income and gain in accordance with Treasury Regulations Section 1.704-2(f). For purposes of this Agreement, the term “Company 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 Company Minimum Gain shall be determined in accordance with Treasury Regulations Section 1.704-2(g)(1). This Section 8.3(a) 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.

Appears in 1 contract

Samples: Limited Liability Company Agreement (CNL Growth Properties, Inc.)

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