Common use of Minimum Gain Chargeback (Nonrecourse Liabilities) Clause in Contracts

Minimum Gain Chargeback (Nonrecourse Liabilities). Except as otherwise provided in Regulation Section 1.704-2(c), if there is a net decrease in Partnership Minimum Gain for 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 that Partner’s share of the net decrease in Partnership Minimum Gain. The items to be so allocated shall be determined in accordance with Regulation Section 1.704-2(f). This Section 11.2(a) is intended to comply with the minimum gain chargeback requirement in said section of the regulations and shall be interpreted consistently therewith. Allocations pursuant to this paragraph shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant hereto.

Minimum Gain Chargeback (Nonrecourse Liabilities). Except as otherwise provided in Regulation Treasury Regulations Section 1.704-2(c2(f), if there is a net decrease in Partnership Minimum Gain for during any Partnership fiscal year, each Partner the Partners shall be specially allocated items of Partnership income and gain for such year (and, and if necessary, necessary in subsequent years) in an amount equal to that each Partner’s share of the net decrease in Partnership Minimum Gain. The items to be so allocated shall be , determined in accordance with Regulation Treasury Regulations Section 1.704-2(f2(g). This Section 11.2(a) is intended to comply with the minimum gain chargeback requirement in said section of the regulations and shall be interpreted consistently therewith. Allocations pursuant to this paragraph the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant heretoPartner. The items to be so allocated shall be determined in accordance with Treasury Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2). This subsection is intended to comply with the minimum gain chargeback requirement in Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.