Deficit Account Chargeback and Qualified Income. If any Partner has ----------------------------------------------- an Adjusted Capital Account Deficit at the end of any year, including an Adjusted Capital Account Deficit for such Partner caused or increased by an adjustment, allocation or distribution described in Regulation Section 1.704- 1(b)(2)(ii)(d)(4), (5) or (6), such Partner shall be allocated items of income and gain (consisting of a pro rata portion of each item of Partnership income, including gross income and gain) in an amount and manner sufficient to eliminate such Adjusted Capital Account Deficit as quickly as possible. This subsection ---------- (c) is intended to constitute a ---
Appears in 2 contracts
Samples: Limited Partnership Agreement (Lyondell Chemical Co), Limited Partnership Agreement (Equistar Chemicals Lp)
Deficit Account Chargeback and Qualified Income. If any Partner ----------------------------------------------- has ----------------------------------------------- an Adjusted Capital Account Deficit at the end of any year, including an Adjusted Capital Account Deficit for such Partner caused or increased by an adjustment, allocation or distribution described in Regulation Section 1.704- (S)(S)1.704-1(b)(2)(ii)(d)(4), (5) or (6), such Partner shall be allocated items of income and gain (consisting of a pro rata portion of each item of Partnership income, including gross income and gain) in an amount and in a manner sufficient to eliminate such Adjusted Capital Account Deficit as quickly as possible. This subsection ---------- (cSection 4.1(j) is intended to constitute a ----------------- "qualified income offset" pursuant to Regulation (S)1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.
Appears in 1 contract
Samples: Limited Partnership Agreement (Lyondell Chemical Co)
Deficit Account Chargeback and Qualified Income. If any Partner has an ----------------------------------------------- an Adjusted Capital Account Deficit at the end of any year, including an Adjusted Capital Account Deficit for such Partner caused or increased by an adjustment, allocation or distribution described in Regulation Section 1.704- (S)1.704-1(b)(2)(ii)(d)(4), (5) or (6), such Partner shall be allocated items of income and gain (consisting of a pro rata portion of each item of Partnership income, including gross income and gain) in an amount and manner sufficient to eliminate such Adjusted Capital Account Deficit as quickly as possible. This subsection ---------- (c) is intended to -------------- constitute a ---"qualified income offset" pursuant to Regulation (S)1.704- 1(b)(2)(ii)(d) and shall be interpreted consistently therewith.
Appears in 1 contract
Samples: Limited Partnership Agreement (Equistar Funding Corp)