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

Minimum Gain Attributable to Partner Nonrecourse Debt. Except as ----------------------------------------------------- otherwise provided in Treasury Regulations Section 1.704-2(i), if there is a net decrease in Minimum Gain Attributable to Partner Nonrecourse Debt during any Partnership Fiscal Year, each Partner with a share of Minimum Gain Attributable to Partner Nonrecourse Debt shall be specially allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in proportion to, and to the extent of, an amount equal to the portion of such Partner's share of the net decrease in the Minimum Gain Attributable to Partner Nonrecourse Debt, determined in accordance with Treasury Regulations Section 1.704-2(i)(4). This Section 3.4 is intended to comply with the chargeback of items of income and gain requirement in Treasury Regulations Section 1.704- 2(i)(4) and shall be interpreted consistently therewith.

Minimum Gain Attributable to Partner Nonrecourse Debt. Except as ----------------------------------------------------- otherwise provided in Treasury Regulations Section 1.704-2(i), if If there is a net decrease in Minimum Gain Attributable minimum gain attributable to “Partner Nonrecourse Debt Debt” (as defined in Section 1.704-2(b)(4) of the Treasury Regulations) applicable to the Partnership during any Partnership Fiscal Year, each Partner with a share of Minimum Gain Attributable to Partner Nonrecourse Debt shall be specially allocated items of Partnership income and gain for such period year (and, if necessary, subsequent periodsyears) in proportion to, and to the extent of, an amount equal to the portion of such that Partner's ’s share of the net decrease in the Minimum Gain Attributable minimum gain attributable to Partner Nonrecourse Debt, as determined under Section 1.704-2(i)(5) of the Treasury Regulations. The items to be so allocable shall be determined in accordance with Section 1.704- 2(i)(4) of the Treasury Regulations Section 1.704-2(i)(4)Regulations. This Section 3.4 paragraph is intended to comply with the minimum gain chargeback requirement with respect to Partner Nonrecourse Debt contained in said section of items of income and gain requirement in the Treasury Regulations Section 1.704- 2(i)(4) and shall be interpreted consistently therewith.