Common use of Chargeback of Minimum Gain Attributable to Partner Nonrecourse Debt Clause in Contracts

Chargeback of Minimum Gain Attributable to Partner Nonrecourse Debt. Notwithstanding the other provisions of this Section 5.1 (other than 5.1(e)(i)), except as provided in Treasury Regulation Section 1.704-2(i)(4) if there is a net decrease in Minimum Gain Attributable to Partner Nonrecourse Debt during any Partnership taxable period, any Partner with a share of Minimum Gain Attributable to Partner Nonrecourse Debt at the beginning of such taxable period shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(i)(4) and 1.704-2(j)(ii), or any successor provisions. For purposes of this Section 5.1, each Partner’s Adjusted Capital Account balance shall be determined and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 5.1(e), other than Section 5.1(e)(i), with respect to such taxable period.

Chargeback of Minimum Gain Attributable to Partner Nonrecourse Debt. Notwithstanding the other provisions of this Section 5.1 Article IV (other than 5.1(e)(iSection 4.3(a)), except as provided in Treasury Regulation Regulations Section 1.704-2(i)(4) ), if there is a net decrease in Minimum Gain Attributable minimum gain attributable to Partner Nonrecourse Debt partner nonrecourse debt (as defined in Regulation Section 1.704-2(i)(3)) during any Partnership taxable period, any Partner with a share of Minimum Gain Attributable minimum gain attributable to Partner Nonrecourse Debt partner nonrecourse debt at the beginning of such taxable period shall be allocated items of Partnership income and gain for such period (and, and if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Regulations Sections 1.704-2(i)(4) and 1.704-2(j)(ii2(j)(2)(ii), or any successor provisions. For purposes of this Section 5.1Article IV, each Partner’s Adjusted Partner‟s adjusted Capital Account balance shall be determined and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 5.1(e)4.3, other than Section 5.1(e)(i4.3(a) and other than an allocation pursuant to Section 4.3(e), with respect to such taxable period.

Chargeback of Minimum Gain Attributable to Partner Nonrecourse Debt. Notwithstanding the other provisions of this Section 5.1 (other than 5.1(e)(i)Section 5.1(d), except as provided in Treasury Regulation Section section 1.704-2(i)(4) )), if there is a net decrease in Minimum Gain Attributable to Partner Nonrecourse Debt during any Partnership such taxable period, any Partner Party with a share of Minimum Gain Attributable to Partner Nonrecourse Debt at the beginning of such taxable period shall will be allocated items of Partnership Company income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections sections 1.704-2(i)(4) and 1.704-2(j)(ii2(j)(2)(ii), or any successor provisions. For purposes of this Section 5.1, each PartnerParty’s Adjusted Capital Account balance shall will be determined and the allocation of income or gain required hereunder shall will be effected, prior to the application of any other allocations pursuant to this Section 5.1(e)5.1, other than Section 5.1(e)(iSections 5.1(d), (h) and (i), with respect to such taxable period.

Chargeback of Minimum Gain Attributable to Partner Nonrecourse Debt. Notwithstanding the other provisions of this Section 5.1 4.1 (other than 5.1(e)(i)Section 4.1(d), except as provided in Treasury Regulation Section Regulations section 1.704-2(i)(4) )), if there is a net decrease in Minimum Gain Attributable to Partner Nonrecourse Debt during any Partnership taxable period, any Partner with a share of Minimum Gain Attributable to Partner Nonrecourse Debt at the beginning of such taxable period shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections Regulations sections 1.704-2(i)(4) and 1.704-2(j)(ii2(j)(2)(ii), or any successor provisions. For purposes of this Section 5.14.1, each such Partner’s Adjusted Capital Account balance shall be determined and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 5.1(e)4.1, other than Section 5.1(e)(iSections 4.1(d), (h) and (i), with respect to such taxable period.

Chargeback of Minimum Gain Attributable to Partner Nonrecourse Debt. Notwithstanding the other provisions of this Section 5.1 4.1 (other than 5.1(e)(i)Section 4.1(c), except as provided in Treasury Regulation Section Regulations section 1.704-2(i)(4) )), if there is a net decrease in Minimum Gain Attributable to Partner Nonrecourse Debt during any Partnership taxable period, any Partner with a share of Minimum Gain Attributable to Partner Nonrecourse Debt at the beginning of such taxable period shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections Regulations sections 1.704-2(i)(4) and 1.704-2(j)(ii2(j)(2)(ii), or any successor provisions. For purposes of this Section 5.14.1, each such Partner’s Adjusted Capital Account balance shall be determined and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 5.1(e)4.1, other than Section 5.1(e)(iSections 4.1(c), (g) and (h), with respect to such taxable period.