If any taxes, penalties or interest are imposed on the Company by a Governmental Authority (including, without limitation, any such amounts under Sections 6221 through 6241 of the Code, as in effect for tax years beginning after December 31, 2017) that are specifically attributable to a Member, then such Member (the “ Indemnifying Member ”) shall indemnify the Company in full for the entire amount paid to such Governmental Authority (including, without limitation, any expenses associated with such payments). The Indemnifying Member shall promptly after receipt by the Indemnifying Member of written notification from the Company of an obligation to indemnify the Company, but in any event not later than the next date on which Available Cash will be distributed to the Members pursuant to Section 4.1.1(b) (the “ Next Distribution Date ”), make a cash payment to the Company equal to the full amount to be indemnified (provided that the amount paid shall not be treated as a Capital Contribution). If the Indemnifying Member does not make such payment to the Company as provided in the preceding sentence, then the Company shall reduce distributions that would otherwise be made to the Indemnifying Member on the Next Distribution Date pursuant to Section 4.1.1(b), until the Company has recovered the full amount to be indemnified (provided that the amount of such reduction shall be deemed to have been distributed for all purposes of this Agreement), provided however, if the amount of such reduction is not sufficient for the Company to recover the full amount to be indemnified, the Indemnifying Member shall make a cash payment to the Company in an amount equal to the balance amount to be indemnified within three (3) Business Days following the Next Distribution Date (provided that the amount paid shall not be treated as a Capital Contribution).