Common use of Minimum Gain Chargeback Clause in Contracts

Minimum Gain Chargeback. Notwithstanding the provisions of Section 5.1 of the Agreement, if there is a net decrease in Partnership Minimum Gain during any Partnership 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 such Partner’s share of the net decrease in Partnership Minimum Gain, as determined under Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Section 1.704-2(f)(6). This Section 5.1(c)(i) is intended to comply with the minimum gain chargeback requirements in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding the provisions of Section 5.1 of the Agreement, if there is a net decrease in Partnership Minimum Gain during any Partnership 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 such Partner’s share of the net decrease in Partnership Minimum Gain, as determined under Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Section 1.704-2(f)(62(0(6). This Section 5.1(c)(i) is intended to comply with the minimum gain chargeback requirements in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding the provisions of Section 5.1 of the Agreement, if If there is a net decrease in Partnership Minimum Gain or Partner Nonrecourse Debt Minimum Gain (determined in accordance with the principles of Regulations Sections 1.704-2(d) and 1.704-2(i)) during any Partnership Yeartaxable year, each Partner the Partners shall be specially allocated items of Partnership income and gain for such year (and, if necessary, subsequent years) in an amount equal to their respective shares of such Partner’s share of the net decrease in Partnership Minimum Gainduring such year, as determined under pursuant to Regulations Section Sections 1.704-2(g) and 1.704-2(i)(5). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Section 1.704-2(f)(62(f). This Section 5.1(c)(i) is intended to comply with the minimum gain chargeback requirements in such U.S. Regulations Section 1.704-2(f) Sections and shall be interpreted consistently therewith, including that no chargeback shall be required to the extent of the exceptions provided in Regulations Sections 1.704-2(f) and 1.704-2(i)(4).

Minimum Gain Chargeback. Notwithstanding the provisions of Section 5.1 of the Agreement, if If there is a net decrease in Partnership Minimum Gain or Partner Nonrecourse Debt Minimum Gain (determined in accordance with the principles of Regulations Sections 1.704-2(d) and 1.704-2(i)) during any Partnership Yeartaxable year, each Partner the Partners shall be specially allocated items of Partnership income and gain for such year (and, if necessary, subsequent years) in an amount equal to their respective shares of such Partner’s share of the net decrease in Partnership Minimum Gainduring such year, as determined under pursuant to Regulations Section Sections 1.704-2(g) and 1.704-2(i)(5). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Section 1.704-2(f)(62(f). This Section 5.1(c)(i) is intended to comply with the minimum gain chargeback requirements in such Regulations Section 1.704-2(f) Sections and shall be interpreted consistently therewith, including that no chargeback shall be required to the extent of the exceptions provided in Regulations Sections 1.704-2(f) and 1.704-2(i)(4).

Minimum Gain Chargeback. Notwithstanding the provisions of Except as otherwise provided in Regulations Section 5.1 of the Agreement1.704-2(f), if there is a net decrease in Partnership Minimum Gain during any Partnership 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 such Partner’s 's share of the net decrease in Partnership Minimum Gain, as determined under Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Section Sections 1.704-2(f)(6) and 1.704-2(j)(2). This Section 5.1(c)(i6.2.B(1) is intended to comply with the qualify as a "minimum gain chargeback requirements in Regulations chargeback" within the meaning of Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding the provisions of Section 5.1 of the Agreement, if there is a net decrease in Partnership Minimum Gain during any Partnership 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 such Partner’s share of the net decrease in Partnership Minimum Gain, as determined under Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Section 1.704-2(f)(6). This Section 5.1(c)(i) is intended to comply with the minimum gain chargeback requirements in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith).

Minimum Gain Chargeback. Notwithstanding the provisions of Section 5.1 of the Agreement, if there is a net decrease in Partnership Minimum Gain during any Partnership 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 such Partner’s share of the net decrease in Partnership Minimum Gain, as determined under Regulations Section 1.704-1.704- 2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Section 1.704-2(f)(6). This Section 5.1(c)(i) is intended to comply with the minimum gain chargeback requirements in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding the provisions of this Section 5.1 of the Agreement5.1, if there is a net decrease in Partnership Minimum Gain during any Partnership 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 such Partner’s share of the net decrease in Partnership Minimum Gain, as determined under Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Section 1.704-2(f)(62(f). This Section 5.1(c)(i) is intended to comply with the minimum gain chargeback requirements in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding the any other provisions of Section 5.1 of the Agreementthis Allocations Exhibit, if there is a net decrease in Partnership Minimum Gain during any Partnership 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 such Partner’s 's share of the net decrease in Partnership Minimum Gain, as determined under Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Section 1.704-2(f)(6). This Section 5.1(c)(i) Section 3.1 is intended to comply with the minimum gain chargeback requirements in of Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding the provisions of Section 5.1 of the Agreement, if there is a net decrease in Partnership Minimum Gain during any Partnership 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 such Partner’s 's share of the net decrease in Partnership Minimum Gain, as determined under Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Section 1.704-2(f)(62(0(6). This Section 5.1(c)(i) is intended to comply with the minimum gain chargeback requirements in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding the provisions of this Section 5.1 of the Agreement5.1, if there is a net decrease in Partnership Minimum Gain during any Partnership 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 such Partner’s 's share of the net decrease in Partnership Minimum Gain, as determined under Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Section 1.704-2(f)(62(0(6). This Section 5.1(c)(i) is intended to comply with the minimum gain chargeback requirements in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding the provisions of Section 5.1 of the Agreement, if If there is a net decrease in Partnership Minimum Gain during any Partnership Allocation Year, each Partner shall be specially allocated items of Partnership income and gain for such year Allocation Year (and, if necessary, subsequent yearsAllocation Years) in proportion to, and to the extent of, an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, as determined under in accordance with Treasury Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be so allocated to each Partner pursuant thereto. The items to be so allocated shall will be determined in accordance with Treasury Regulations Section Sections 1.704-2(f)(6) and 1.704-20)(2). This Section 5.1(c)(i3.2(a) is intended to comply with the minimum gain chargeback requirements requirement in Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding the provisions any other provision of Section 5.1 of the Agreementthis §4, if there is a net decrease in Partnership Minimum Gain during any Partnership Yearfiscal 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 the portion of such Partner’s share of the net decrease in Partnership Minimum Gain, as determined under in accordance with Regulations Section §1.704-2(g2 (g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Section §1.704-2(f)(6)2 (f) (6) of the Regulations. This Section 5.1(c)(i) §4. 3.1 is intended to comply with the minimum gain chargeback requirements requirement in such Section of the Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding the provisions of Except as otherwise provided in Section 5.1 1.704-2(f) of the AgreementRegulations, if in the event there is a net decrease in Partnership Minimum Gain (within the meaning of Section 1.704-2(b)(2) of the Regulations) during any a Partnership Yeartaxable year, each Partner shall be specially allocated (before any other allocation is made pursuant to Section 5.4 of this Agreement) items of Partnership income and gain for such year (and, if necessary, for subsequent years) in an amount equal to such that Partner’s share of the net decrease in Partnership Minimum Gain, as determined under Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated determination of a Partner’s share of the net decrease in Partnership Minimum Gain shall be determined in accordance with Regulations Section 1.704-2(g) of the Regulations. The items to be specially allocated to the Partners in accordance with this Section 5.5A. shall be determined in accordance with Section 1.704-2(f)(6)) of the Regulations. This Section 5.1(c)(i) 5.5A. is intended to comply with the minimum gain Minimum Gain chargeback requirements requirement set forth in Regulations Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding the any other provisions of Section 5.1 of the AgreementArticle VI, if there is a net decrease in Partnership Minimum Gain during any Partnership 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 such Partner’s 's share of the net decrease in Partnership Minimum Gain, as determined under Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Section 1.704-2(f)(6). This Section 5.1(c)(i6.2 (a) is intended to comply with the minimum gain chargeback requirements in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding the provisions any other provision of Section 5.1 of the Agreementthis Article 5, if there is a net decrease in Partnership Minimum Gain during any Partnership YearFiscal Year or other applicable period, then, subject to the exceptions set forth in Regulations Section 1.704-2(f)(2), (3), (4) and (5), each Partner shall be specially allocated items of Partnership income and gain for such year Partnership Fiscal Year (and, if necessary, subsequent yearsPartnership Fiscal Years) in an amount equal to such Partner’s 's share of the net decrease in Partnership Minimum Gain, as determined under in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Section 1.704-2(f)(62(f). This Section 5.1(c)(i5.2(a)(1) is intended to comply with the minimum gain chargeback requirements requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding the provisions of Section 5.1 any other provision of the Agreementforegoing Sections 2(A) and (B), if there is a net decrease in Partnership Minimum Gain during any Partnership Fiscal Year, then, to the extent required by Regulations Section 1.704-2(f), 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 such Partner’s 's share of the net decrease in Partnership Minimum Gain, as determined under in accordance with Regulations Section 1.704-2(g2(g)(2). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Section Sections 1.704-2(f)(6) and 1. 704-2(j). This Section 5.1(c)(i2(C)(1) is intended to comply with the minimum gain chargeback requirements requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding the provisions of this Section 5.1 of the Agreement5.01, if there is a net decrease in Partnership Minimum Gain during any Partnership 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 such Partner’s share of the net decrease in Partnership Minimum Gain, as determined under Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Section 1.704-2(f)(62(f). This Section 5.1(c)(i5.01(c)(i) is intended to comply with the minimum gain chargeback requirements in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding the provisions of Except as otherwise provided in Regulations Section 5.1 of the Agreement1.704-2(f), if there is a net decrease in Partnership Minimum Gain during any Partnership 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 such Partner’s 's share of the net decrease in Partnership Minimum Gain, as determined under Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Section Sections 1.704- 2(f)(6) and 1.704-2(f)(62(j). This Section 5.1(c)(i) is intended to comply with the minimum gain chargeback requirements in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding the provisions of this Section 5.1 of the Agreement5.1, if there is a net decrease in Partnership Minimum Gain during any Partnership 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 such Partner’s share of the net decrease in Partnership Minimum Gain, as determined under Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Section 1.704-2(f)(62(0(6). This Section 5.1(c)(i) is intended to comply with the minimum gain chargeback requirements in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding the provisions of Section 5.1 of the Agreement, if If there is a net decrease in Partnership Minimum Gain during any Partnership Allocation Year, each Partner shall be specially allocated items of Partnership income and gain for such year Allocation Year (and, if necessary, subsequent yearsAllocation Years) in proportion to, and to the extent of, an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, as Gain determined under in accordance with Treasury Regulations Section 1.704-2(g2(g)(2). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be so allocated to each Partner pursuant thereto. The items to be so allocated shall will be determined in accordance with Treasury Regulations Section Sections 1.704-2(f)(6) and 1.704-2(j)(2). This Section 5.1(c)(i6.2(a) is intended to comply with the minimum gain chargeback requirements requirement in Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.