If the Company incurs a withholding tax obligation with respect to the share of income allocated to any Member, (a) any amount which is (i) actually withheld from a distribution that would otherwise have been made to such Member and (ii) paid over to the Internal Revenue Service or state or local taxing authority in satisfaction of such withholding tax obligation shall be treated for all purposes under this Agreement as if such amount had been distributed to such Member, and (b) any amount which is paid over to the Internal Revenue Service or state or local taxing authority by the Company in satisfaction of such withholding obligation, but which exceeds the amount, if any, actually withheld from a distribution which would otherwise have been made to such Member, shall be treated as an advance to such Member. Amounts treated as advanced to any Member pursuant to clause(b) of this Section 8.04 shall be repaid by such Member to the Company within thirty (30) days after any Member gives notice to such Member making demand therefor. Any amounts so advanced and not timely paid shall bear interest, commencing on the expiration of said thirty (30) day period, at a rate equal to the lesser of (x) twenty percent (20%) per annum or (y) the highest rate which may be charged under applicable law, in each case compounded monthly. The Company shall collect any unpaid amounts due under this Section 8.04 from any Company distributions that would otherwise be made to such Member.