Minimum Gain. The term “Minimum Gain” shall mean the aggregate amount of gain, if any, that would be realized by the Company if, in a taxable transaction, it disposed of all Company property subject to Nonrecourse Liabilities of the Company (as defined in Regulations Section 1.704-2(b)(3)) in full satisfaction thereof (and for no other consideration). The Partners intend that Minimum Gain on Nonrecourse Liability shall be determined in accordance with the provisions of Regulations Section 1.704-2(d)(1).
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Samples: Limited Partnership Agreement, Partnership Agreement, Limited Partnership Agreement (Strategic Hotel Capital Inc)
Minimum Gain. The term “Minimum Gain” shall mean means, with respect to each Non-recourse Liability of the aggregate Company, the amount of gain, if any, gain (of whatever character) that would be realized by the Company if, in a taxable transaction, if it disposed of all the Company property subject to Nonrecourse Liabilities of the Company (as defined such liability in Regulations Section 1.704-2(b)(3)) a taxable transaction in full satisfaction thereof of such liability (and for no other consideration), and by then aggregating the amounts so computed. The Partners intend It is further understood that Minimum Gain on Nonrecourse Liability shall be determined in accordance a manner consistent with the provisions rules of Regulations Treasury Regulation Section 1.704-2(d)(12(d)(2) (or successor provisions).
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