Common use of Disposition of partnership interest Clause in Contracts

Disposition of partnership interest. If an S corporation disposes of its part- nership interest, the amount that may be treated as recognized built-in gain may not exceed the excess (if any) of the S corporation’s RBIG limitation over its partnership RBIG during the recognition period. Similarly, the amount that may be treated as recog- nized built-in loss may not exceed the excess (if any) of the S corporation’s RBIL limitation over its partnership RBIL during the recognition period.