Minimum Gain Chargeback—Partner Nonrecourse Debt. If there is a net decrease in Partner Minimum Gain during any Partnership taxable year, certain items of income and gain shall be allocated (on a gross basis) as quickly as possible to those Partners that had a share of the Partner Minimum Gain (determined pursuant to Section 1.704-2(i)(5) of the Regulations) in the amounts and manner described in Section 1.704-2(i)(4), (j)(2)(ii) and (iii) of the Regulations. This Section 5.2(b) is intended to comply with the minimum gain chargeback requirement (set forth in Section 1.704-2(i)(4) of the Regulations) relating to partner nonrecourse debt (as defined in Section 1.704-2(b)(4) of the Regulations) and shall be so interpreted.
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Samples: Limited Partnership Agreement (Interstate Hotels Corp), Distribution and Contribution Agreement (Interstate Hotels & Resorts Inc), Distribution and Contribution Agreement (Interstate Hotels & Resorts Inc)
Minimum Gain Chargeback—Partner Nonrecourse Debt. If there is a net decrease in Partner Minimum Gain during any Partnership taxable yearFiscal Year, certain items of income and gain shall be allocated (on a gross basis) as quickly as possible to those Partners that who had a share of the Partner Minimum Gain (determined pursuant to Regulations Section 1.704-2(i)(5) of the Regulations)) in the amounts and manner described in Regulations Section 1.704-2(i)(4), (j)(2)(ii) ), and (iii) of the Regulationsj)(2)(iii). This Section 5.2(b4.2(b) is intended to comply with the minimum gain chargeback requirement (set forth in Regulations Section 1.704-2(i)(4) of the Regulations)) relating to partner nonrecourse debt (as defined in Regulations Section 1.704-2(b)(4) of the Regulations)) and shall be so interpreted.
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Samples: Limited Partnership Agreement (Southern Foods Group L P)
Minimum Gain Chargeback—Partner Nonrecourse Debt. If there is a net decrease in Partner Minimum Gain during any Partnership taxable year, certain items of income and gain shall be allocated (on a gross basis) as quickly as possible to those Partners that who had a share of the Partner Minimum Gain (determined pursuant to Section 1.704-2(i)(5) of the Regulations) in the amounts and manner described in Section 1.704-2(i)(4), (j)(2)(ii) and (iii) of the Regulations. This Section 5.2(b4.3(a)(ii) is intended to comply with the minimum gain chargeback requirement (set forth in Section 1.704-2(i)(4) of the Regulations) relating to partner nonrecourse debt (as defined in Section 1.704-2(b)(4) of the Regulations) and shall be so interpreted.
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Samples: Limited Partnership Agreement (Young Touchstone Co)
Minimum Gain Chargeback—Partner Nonrecourse Debt. If there is a net decrease in Partner Minimum Gain during any Partnership taxable year, certain items of income and gain shall be allocated (on a gross basis) as quickly as possible to those Partners that who had a share of the Partner Minimum Gain (determined pursuant to Section section 1.704-2(i)(5) of the Regulations) in the amounts and manner described in Section section 1.704-2(i)(4), (j)(2)(ii) and (iii) of the Regulations. This Section 5.2(b) is intended to comply with the minimum gain chargeback requirement (set forth in Section section 1.704-2(i)(4) of the Regulations) relating to partner nonrecourse debt (as defined in Section section 1.704-2(b)(4) of the Regulations) and shall be so interpreted.
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Minimum Gain Chargeback—Partner Nonrecourse Debt. If there is a net decrease in Partner Minimum Gain during any Partnership taxable yearFiscal Year, certain items of income and gain shall be allocated (on a gross basis) as quickly as possible to those Partners that who had a share of the Partner Minimum Gain (determined pursuant to Regulations Section 1.704-2(i)(5) of the Regulations)) in the amounts and manner described in Regulations Section 1.704-2(i)(4), (j)(2)(ii) ), and (iii) of the Regulationsj)(2)(iii). This Section 5.2(b) is intended to comply with the minimum gain chargeback requirement (set forth in Regulations Section 1.704-2(i)(4) of the Regulations)) relating to partner nonrecourse debt (as defined in Regulations Section 1.704-2(b)(4) of the Regulations)) and shall be so interpreted.
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