Allocations Required by Treasury Regulations. (i) (A) Subject to the exceptions set forth in Treas. Reg. §§1.7042(f)(2)-(5), if there is a net decrease in Minimum Gain during any fiscal year, each Partner shall be specially allocated items of Partnership income and gain for such year (and, if necessary, subsequent years) in an amount equal to such Partner’s share of the net decrease in Minimum Gain, determined in accordance with Treas. Reg. §1.704-2(g)(2). “Minimum Gain” shall have the meaning set forth in Treas. Reg. §§1.704-2(b)(2) and 1.704-2(d). This paragraph is intended to comply with the minimum gain chargeback requirement in Treas. Reg. §§1.704-2(b)(2) and (f) and shall be interpreted consistently therewith.
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Samples: Partnership Agreement, Agreement of Limited Partnership (Adesa California, LLC)
Allocations Required by Treasury Regulations. (i) (Aa) Subject to the exceptions set forth in Treas. Reg. §§1.7042(f)(2)-(51.704-2(f)(2)—(5), if there is a net decrease in Minimum Gain during any fiscal yearFiscal Year, each Partner Member shall be specially allocated items of Partnership Company income and gain for such year (and, if necessary, subsequent years) in an amount equal to such PartnerMember’s share of the net decrease in Minimum Gain, determined in accordance with Treas. Reg. §1.704-2(g)(2). “Minimum Gain” shall have the meaning set forth in Treas. Reg. §§1.704-2(b)(2) and 1.704-2(d). This paragraph is intended to comply with the minimum gain chargeback requirement in Treas. Reg. §§1.704-2(b)(2) and (f) and shall be interpreted consistently therewith.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Advanced Drainage Systems, Inc.), Limited Liability Company Agreement (American Railcar Industries, Inc.)
Allocations Required by Treasury Regulations. (i) (A) Subject to the exceptions set forth in Treas. Reg. §§1.7042(f)(2)-(5§ § 1.704-2(f) (2)–(5), if there is a net decrease in Minimum Gain during any fiscal year, each Partner shall be specially allocated items of Partnership income and gain for such year (and, if necessary, subsequent years) in an amount equal to such Partner’s share of the net decrease in Minimum Gain, determined in accordance with Treas. Reg. §1.704-2(g)(2). “Minimum Gain” shall have the meaning set forth in Treas. Reg. §§1.704-2(b)(2) and 1.704-2(d). This paragraph is intended to comply with the minimum gain chargeback requirement in Treas. Reg. §§1.704-2(b)(2) and (f) and shall be interpreted consistently therewith.
Appears in 1 contract
Samples: Limited Partnership Agreement (Michigan's Adventure, Inc.)
Allocations Required by Treasury Regulations. (i) (A) Subject to the exceptions set forth in Treas. Reg. §§1.7042(f)(2)-(51.704-2(f)(2)—(5), if there is a net decrease in Minimum Gain during any fiscal year, each Partner shall be specially allocated items of Partnership income and gain for such year (and, if necessary, subsequent years) in an amount equal to such Partner’s share of the net decrease in Minimum Gain, determined in accordance with Treas. Reg. §§ 1.704-2(g)(2). “Minimum Gain” shall have the meaning set forth in Treas. Reg. §§1.704-2(b)(2) and 1.704l,704-2(d). This paragraph is intended to comply with the minimum gain chargeback requirement in Treas. Reg. §§1.704-2(b)(2) and (f) and shall be interpreted consistently therewith.
Appears in 1 contract
Samples: General Partnership Agreement (Michigan's Adventure, Inc.)
Allocations Required by Treasury Regulations. (i) (Aa) Subject to the exceptions set forth in Treas. Reg. §§1.7042(f)(2)-(51.704-2(f)(2)-(5), if there is a net decrease in Minimum Gain during any fiscal yearFiscal Year, each Partner Member shall be specially allocated items of Partnership Company income and gain for such year (and, if necessary, subsequent years) in an amount equal to such PartnerMember’s share of the net decrease in Minimum Gain, determined in accordance with Treas. Reg. §1.704-2(g)(2). “Minimum Gain” shall have the meaning set forth in Treas. Reg. §§1.704-2(b)(2) and 1.704-2(d). This paragraph is intended to comply with the minimum gain chargeback requirement in Treas. Reg. §§1.704-2(b)(2) and (f) and shall be interpreted consistently therewith.
Appears in 1 contract
Samples: Limited Liability Company Agreement (American Railcar Industries, Inc./De)
Allocations Required by Treasury Regulations. (i) (A) Subject to the exceptions set forth in Treas. Reg. §§1.7042(f)(2)-(51.704-2(f)(2)—(5), if there is a net decrease in Minimum Gain during any fiscal year, each Partner Member shall be specially allocated items of Partnership Company income and gain for such year (and, if necessary, subsequent years) in an amount equal to such PartnerMember’s share of the net decrease in Minimum Gain, determined in accordance with Treas. Reg. §1.704-2(g)(2). “Minimum Gain” shall have the meaning set forth in Treas. Reg. §§1.704-2(b)(2) and 1.704-2(d). This paragraph is intended to comply with the minimum gain chargeback requirement in Treas. Reg. §§1.704-2(b)(2) and (f) and shall be interpreted consistently therewith.
Appears in 1 contract
