Common use of Member Minimum Gain Chargeback Clause in Contracts

Member Minimum Gain Chargeback. Except as otherwise provided in Section 1.704-2(i)(4), in the event there is a net decrease in Member Minimum Gain during a Company taxable year, each Member who has a share of that Member Minimum Gain as of the beginning of the year, to the extent required by Regulation Section 1.704-2(i)(4) shall be specially allocated items of Company income and gain for such year (and, if necessary, subsequent years) equal to that Member’s share of the net decrease in Member Minimum Gain. Allocations pursuant to this subparagraph (b) shall be made in accordance with Regulation Section 1.704-2(i)(4). This Section 8.2(b) is intended to comply with the requirement set forth in Regulation Section 1.704-2(i)(4) and shall be interpreted consistently therewith.

Member Minimum Gain Chargeback. Except as otherwise provided in Notwithstanding any other provision of this Article IV except Section 1.704-2(i)(44.3(a), in the event if there is a net decrease in Member Minimum Gain attributable to a Member Nonrecourse Debt during a Company taxable any fiscal year, then, to the extent required by Regulations Section 1.704-2(i)(4), each Member who has a share of that the Member Minimum Gain as of the beginning of the yearattributable to such Member Nonrecourse Debt, to the extent required by Regulation determined in accordance with Regulations Section 1.704-2(i)(4) 2(i)(5), shall be specially allocated items of Company income and gain for such year (and, if necessary, subsequent years) in an amount equal to that such Member’s share of the net decrease in Member Minimum Gain. Allocations pursuant Gain attributable to this subparagraph (b) shall be made such Member Nonrecourse Debt, determined in accordance with Regulation Regulations Section 1.704-2(i)(4). The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(i)(4) and 1.704‑2(j). This Section 8.2(b4.3(b) is intended to comply with the minimum gain chargeback requirement set forth in Regulation Regulations Section 1.704-2(i)(4) and shall be interpreted consistently therewith.

Member Minimum Gain Chargeback. Except as otherwise provided in Section 1.704-2(i)(4), in the event there is a net decrease in Member Minimum Gain during a Company taxable year, each Member who has a share of that Member Minimum Gain as of the beginning of the year, to the extent required by Regulation Section 1.704-2(i)(4) ), shall be specially allocated items of Company income and gain for such year (and, if necessary, subsequent years) equal to that Member’s share of the net decrease in Member Minimum Gain. Allocations pursuant to this subparagraph (b) shall be made in accordance with Regulation Section 1.704-2(i)(4). This Section 8.2(b7.3(b) is intended to comply with the requirement set forth in Regulation Section 1.704-2(i)(4) and shall be interpreted consistently therewith.

Member Minimum Gain Chargeback. Except as otherwise provided in Regulation Section 1.704-2(i)(4), in the event there is a net decrease in Member Minimum Gain during a Company taxable year, each Member who has a share of that Member Minimum Gain as of the beginning of the year, to the extent required by Regulation Section 1.704-2(i)(4) shall be specially allocated items of Company income and gain for such year (and, if necessary, subsequent years) equal to that Member’s share of the net decrease in Member Minimum Gain. Allocations pursuant to this subparagraph (b) shall be made in accordance with Regulation Section 1.704-2(i)(4). This Section 8.2(bsubsection 8.6(b) is intended to comply with the requirement set forth in Regulation Section 1.704-2(i)(4) and shall be interpreted consistently therewith.

Member Minimum Gain Chargeback. Except as otherwise provided in Regulation Section 1.704-2(i)(4), in the event there is a net decrease in Member Minimum Gain during a Company taxable year, each Member who has a share of that Member Minimum Gain as of the beginning of the year, to the extent required by Regulation Section 1.704-2(i)(4) shall be specially allocated items of Company income and gain for such year (and, if necessary, subsequent years) equal to that Member’s share of the net decrease in Member Minimum Gain. Allocations pursuant to this subparagraph (b) shall be made in accordance with Regulation Section 1.704-2(i)(4). This Section 8.2(b8.4(b) is intended to comply with the requirement set forth in Regulation Section 1.704-2(i)(4) and shall be interpreted consistently therewith.

Member Minimum Gain Chargeback. Except as otherwise provided in Section 1.704-2(i)(4), in the event there is a net decrease in Member Minimum Gain during a Company taxable year, each Member who has a share of that Member Minimum Gain as of the beginning of the year, to the extent required by Regulation Section 1.704-2(i)(4) ), shall be specially allocated items of Company income and gain for such year (and, if necessary, subsequent years) equal to that Member’s share of the net decrease in Member Minimum Gain. Allocations pursuant to this subparagraph (b) shall be made in accordance with Regulation Section 1.704-2(i)(4). This Section 8.2(b7.3(b) is intended to comply with the requirement require­ment set forth in Regulation Section 1.704-2(i)(4) and shall be interpreted consistently therewith.

Member Minimum Gain Chargeback. Except Notwithstanding the other provisions of this Article IV, except as otherwise provided in Regulations Section 1.704-2(i)(4), in the event if there is a net decrease in minimum gain attributable to Member Minimum Gain during a Company taxable year, each Member who has a share of that Member Minimum Gain Nonrecourse Debt (as of the beginning of the year, to the extent required by determined under Regulation Section 1.704-2(i)(42(i)(3)) during any Company taxable period, any Unit Holder with a share of minimum gain attributable to Member Nonrecourse Debt at the beginning of such taxable period shall be specially allocated items of Company income and gain for such year period (and, and if necessary, subsequent yearsperiods) equal to that Member’s share of in the net decrease manner and amounts provided in Member Minimum Gain. Allocations pursuant to this subparagraph (b) shall be made in accordance with Regulation Section Regulations Sections 1.704-2(i)(4) and 1.704-2(j)(2), or any successor provisions. This Section 8.2(b4.3(b) is intended to comply with the minimum gain chargeback requirement set forth in Regulation Section 1.704-2(i)(4) of the Regulations and shall be interpreted consistently therewith.