Member Nonrecourse Debt Minimum Gain Chargeback. If there is a net decrease in Member Nonrecourse Debt Minimum Gain attributable to a Member Nonrecourse Debt during any Company fiscal year, each Member who has a share of the Member Nonrecourse Debt Minimum Gain attributable to such Member Nonrecourse Debt, determined in accordance with Treasury Regulation section 1.704-2(i), 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 Member Nonrecourse Debt Minimum Gain attributable to such Member Nonrecourse Debt, determined in accordance with Treasury Regulation section 1.704-2(i).
Appears in 4 contracts
Samples: Registration Rights Agreement (Forest City Enterprises Inc), Operating Agreement (New York Times Co), Operating Agreement (New York Times Co)
Member Nonrecourse Debt Minimum Gain Chargeback. If Notwithstanding any other provision of this Article IV, if there is a net decrease in Member Nonrecourse Debt Minimum Gain attributable to a Member Nonrecourse Debt during any Company fiscal yearDebt, each the Member who has a share of the Member Nonrecourse Debt Minimum Gain attributable to such Member the Member’s Nonrecourse Debt, determined in accordance with Treasury Regulation section Section 1.704-2(i2(i)(5), 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 the Member’s share of the net decrease in Member Nonrecourse Debt Minimum Gain attributable to such Member Nonrecourse Debt, determined in accordance with Treasury Regulation section Section 1.704-2(i2(i)(4).
Appears in 2 contracts
Samples: Operating Agreement (HTS-Sunset Harbor Partner, L.L.C.), Operating Agreement (HTS-Sunset Harbor Partner, L.L.C.)
Member Nonrecourse Debt Minimum Gain Chargeback. If Notwithstanding any other provision of this Schedule B, if there is a net decrease in Member Nonrecourse Debt Minimum Gain attributable to a Member Nonrecourse Debt during any Company fiscal yearDebt, each Member who has a share of the Member Nonrecourse Debt Minimum Gain attributable to such Member Nonrecourse Debt, determined in accordance with Treasury Regulation section Section 1.704-2(i2(i)(5), 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 share of the net decrease in Member Nonrecourse Debt Minimum Gain attributable to such Member Nonrecourse Debt, determined in accordance with Treasury Regulation section Section 1.704-2(i2(i)(4).
Appears in 1 contract
Samples: Operating Agreement (Jack Miller Family Limited Partnership 1)