Trust Minimum Gain Chargeback. Notwithstanding any other provision of this paragraph (c), if there is a net decrease in Trust Minimum Gain during any Trust taxable period, each Beneficial Owner shall be allocated items of Trust income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. This paragraph (c)(iii)(1) is intended to comply with the Trust Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.
Appears in 7 contracts
Sources: Voting Trust Agreement (Permuto Capital AAPL Trust I), Voting Trust Agreement (Permuto Capital AVGO Trust I), Voting Trust Agreement (Permuto Capital MSFT Trust I)