Common use of Company Minimum Gain Chargeback Clause in Contracts

Company Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulations Section 1.704-2(f), if there is a net decrease in Company Minimum Gain during any Fiscal Year, each Member shall be specially allocated items of Company income and gain for such Fiscal Year (and, if necessary, subsequent Fiscal Years) in an amount equal to such Member’s share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2). This Section 7.2(a)(i) is intended to comply with the minimum gain chargeback requirements set forth in Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulations Section section 1.704-2(f), notwithstanding any other provision of this Article V, if there is a net decrease in Company Minimum Gain during any Fiscal Year, each Member shall be specially allocated items of Company income and gain for such Fiscal Year (and, if necessary, subsequent Fiscal Years) in an amount equal to such Member’s share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulations Section section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Sections sections 1.704-2(f)(6) and 1.704-2(j)(2). This Section 7.2(a)(i5.2(a) is intended to comply with the partnership minimum gain chargeback requirements set forth requirement in Treasury Regulations Section section 1.704-2(f) and shall be interpreted and applied consistently therewith.

Company Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulations Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this Section, if there is a net decrease in Company Minimum Gain during any Fiscal Yeartaxable year, each Member shall be specially allocated items of Company income and gain for such Fiscal Year taxable year (and, if necessary, subsequent Fiscal Yearstaxable years) in an amount equal to such Member’s share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulations Section 1.704-1.704- 2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant theretounder this Section. The items to be so allocated shall be determined in accordance with Treasury Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2)20)(2) of the Regulations. This Section 7.2(a)(i) is intended to comply with the minimum gain chargeback requirements set forth requirement in Treasury Regulations Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewithwith such Regulation.

Company Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulations Section 1.704-2(f), notwithstanding any other provision of this Article 5, if there is a net decrease in Company Minimum Gain during any Fiscal Allocation Year, each Member shall be specially allocated items of Company income and gain for such Fiscal Allocation Year (and, if necessary, subsequent Fiscal Allocation Years) in an amount equal to such Member’s share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2). This Section 7.2(a)(i5.2(a) is intended to comply with the minimum gain chargeback requirements set forth requirement in Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulations Notwithstanding any other provision of this Section 1.704-2(f)7, if there is a net decrease in Company Minimum Gain during any Fiscal Yearcalendar year, then, subject to the exceptions set forth in Regulations Section 1.704-2(f)(2), (3), (4) and (5), each Member shall be specially allocated items of the Company income and gain for such Fiscal Year year (and, if necessary, subsequent Fiscal Yearsyears) in an amount equal to such Member’s share of the net decrease in Company Minimum Gain, as determined in accordance with Treasury under Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Sections Section 1.704-2(f)(6) and 1.704-2(j)(22(f). This Section 7.2(a)(i7.3(b) is intended to comply with the minimum gain chargeback requirements set forth in Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulations Section 1.704-2(f), notwithstanding any other provision of this Article V, if there is a net decrease in Company Minimum Gain (determined according to Regulations Section 1.704-2(d)(1)) during any Fiscal Allocation Year, each Member shall be specially allocated items of Company income and gain for such Fiscal Allocation Year (and, if necessary, subsequent Fiscal Allocation Years) in an amount equal to such Member’s share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2). This Section 7.2(a)(i5.3(a) is intended to comply with the “minimum gain chargeback requirements set forth chargeback” requirement in Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulations Notwithstanding the other provisions of this Section 1.704-2(f)5.1, if there is a net decrease in Company Minimum Gain during any Fiscal YearCompany taxable period, each Member shall be specially allocated items of Company income and gain for such Fiscal Year taxable period (and, if necessary, subsequent Fiscal Yearstaxable periods) in an amount equal to such Member’s share of the net decrease manner and amounts provided in Company Minimum Gain, determined in accordance with Treasury Regulations Section Regulation sections 1.704-2(g2(f)(6) and (g)(2) and section 1.704-2(j)(2)(i), or any successor provisions. Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2). This Section 7.2(a)(i5.1(c)(i) is intended to comply with the minimum gain Company Minimum Gain chargeback requirements set forth requirement in Treasury Regulations Section Regulation section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulations Section 1.704-2(f)) of the Regulations, and notwithstanding any other provision of this Section 7.2, if there is a net decrease in Company Minimum Gain during any Fiscal Yearfiscal year, each Member shall be specially allocated items of Company income and gain for such Fiscal Year fiscal year (and, if necessary, subsequent Fiscal Yearsfiscal years) in an amount equal to such Member’s 's share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Sections 1.704-2(f)(62(f) (6) and 1.704-2(j)(2)) of the Regulations. This Section 7.2(a)(i) 7.2.3 is intended to comply with the minimum gain chargeback requirements set forth requirement in Treasury Regulations Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulations Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this Section 8, if there is a net decrease in Company Minimum Gain during any Fiscal Yearfiscal year, each Member shall be specially allocated items of Company income and gain for such Fiscal Year fiscal year (and, if necessary, subsequent Fiscal Yearsfiscal years) in an amount equal to such Member’s 's share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulations Section 1.704-1.704- 2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Sections Section 1.704-2(f)(6) and 1.704-2(j)(2)) of the Regulations. This Section 7.2(a)(i8(c)(i) is intended to comply with the minimum gain chargeback requirements set forth requirement in Treasury Regulations Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulations Section 1.704-2(f), notwithstanding the provisions of Section 2.2(a), if there is a net decrease in Company Minimum Gain during any Fiscal Year, each Member Partner shall be specially allocated items of Company income and gain for such Fiscal Year (and, if necessary, subsequent Fiscal Years) in an amount equal to such MemberPartner’s share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2). This Section 7.2(a)(i2.2(b)(i) is intended to comply with the partnership minimum gain chargeback requirements set forth requirement in Treasury Regulations Section 1.704-2(f) and shall be interpreted and applied consistently therewith.

Company Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulations Section section 1.704-2(f), notwithstanding any other provision of this Article VI, if there is a net decrease in Company Minimum Gain during any Fiscal Year, each Member shall be specially allocated items of Company income and gain for such Fiscal Year (and, if necessary, subsequent Fiscal Years) in an amount equal to such Member’s share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulations Section section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Sections sections 1.704-2(f)(6) and 1.704-2(j)(2). This Section 7.2(a)(i6.2(a) is intended to comply with the partnership minimum gain chargeback requirements set forth requirement in Treasury Regulations Section section 1.704-2(f) and shall be interpreted and applied consistently therewith.

Company Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulations Section 1.704-2(f), notwithstanding any other provision of this Article 5, if there is a net decrease in Company Minimum Gain during any Fiscal Allocation Year, each Member shall be specially allocated items of Company income and gain for such Fiscal Allocation Year (and, if necessary, subsequent Fiscal Allocation Years) in an amount equal to such Member’s 's share of the net decrease in Company Minimum Gain, determined in accordance with Treasury Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2). This Section 7.2(a)(i5.2(a) is intended to comply with the minimum gain chargeback requirements set forth requirement in Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Company Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulations Section 1.704-2(f), notwithstanding any other provision of this Section 5.3, if there is a net decrease in Company Minimum Gain during any Fiscal YearTaxable Period, each Member shall be specially allocated items of Company income and gain for such Fiscal Year Taxable Period (and, if necessary, subsequent Fiscal YearsTaxable Periods) in an amount equal to such Member’s share of the such net decrease in Company Minimum GainGain during such Taxable Period, determined in accordance with Treasury Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2). This Section 7.2(a)(i5.3(c)(i)(A) is intended to comply with the minimum gain chargeback requirements set forth in Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.