Minimum Gain Chargebacks. In order to comply with the "minimum gain chargeback" requirements of Regulation Sections 1.704-2(f)(l) and 1.704-2(I)(4), and notwithstanding any other provision of this Agreement to the contrary, in the event there is a net decrease in an Interest Holder's share of Minimum Gain and/or Member Nonrecourse Debt Minimum Gain during a Company's taxable year, such Interest Holder shall be allocated items of income and gain for that year (and if necessary, other years) as required by and in accordance with Regulation Sections 1.704-2(f)(l) and 1.704-2(I)(4) before any other allocation is made. It is the intent of the parties hereto that any allocation pursuant to this Section 4.3.2 shall constitute a "minimum gain chargeback" under Regulation Section 1.704-2(f) and 1.704-2(I)(4).
Minimum Gain Chargebacks. Items of Company income and gain shall be allocated among the Shareholders at such times and in such manner as may be necessary to satisfy the minimum gain chargeback requirements of U.S. Treasury Regulations Sections 1.704-2(f) and 1.704-2(i)(4).
Minimum Gain Chargebacks. Notwithstanding Section 4.1, Profits (including any gross income or gains) shall be allocated and shared between or among the Members so as to comply with the “minimum gain chargeback” provisions in Treas. Reg. § 1.704–2 (applicable to partnership non-recourse debt or partner non-recourse debt, as the case may be).
Minimum Gain Chargebacks. Items of Company income and gain shall be allocated for any Fiscal Year to the extent, and in an amount sufficient to satisfy the “minimum gain chargeback” requirements of Treasury Regulation Sections 1.704-2(f) and (i)(4).
Minimum Gain Chargebacks. The Managing Member shall make such ------------------------ allocations of items of income and gain as are necessary to comply with the "minimum gain chargeback" provisions of Section 1.704-2(f) of the Treasury Regulations or any successor provisions thereto.
Minimum Gain Chargebacks. If during any taxable year there is a net decrease in partnership minimum gain (as such term is defined by Regulations §1.704-2(d)), then each Partner will be specially allocated gross income for such taxable year (and, if necessary, for subsequent taxable years) in the manner provided in Regulations §1.704-2(f). Likewise, if there is a net decrease during any taxable year in the minimum gain attributable to Partner nonrecourse debt (as defined in Regulations §1.704-2(i)(3)) with respect to Partner nonrecourse debt, then any Partner with a share of the minimum gain attributable to such debt at the beginning of such taxable year shall be specially allocated items of gross income for such taxable year (and, if necessary, for subsequent taxable years) in the manner provided in Regulations §1.704-2(i)(4). This Section 7.3(a) is intended to comply with, and shall be interpreted to be consistent with, the minimum gain chargeback requirements of Regulations §§1.704-2(f) and 1.704-2(i). LPA | 28
Minimum Gain Chargebacks. If there is a net decrease in either LLC Minimum Gain or minimum gain attributable to a Member Nonrecourse Debt during a LLC taxable year, each Member shall be allocated items of income and gain in accordance with the requirements of ss. ss. 1.7042(9)(2) and 1.7042(i)(5) of the Treasury Regulations. "LLC Minimum Gain" means LLC minimum gain computed in accordance with the principles of ss. 1.7042(d) of the Treasury Regulations.
Minimum Gain Chargebacks. Notwithstanding any other provision of this Article V, if there is a net decrease in Partnership Minimum Gain during any Partnership fiscal year, each Partner who has a share of Partnership Minimum Gain determined in accordance with Treas. Reg. §1.704-2(g)(1) 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 provided by Treas. Reg. §1.704-2(g)(2). The items to be so allocated shall be determined in accordance with Regulation Section 1.704-2(f) and 1.704-2(j)(2)(i). The terms of this Section 5.05(a) are intended to comply with the minimum gain charge back requirements in such Sections of the Regulations and shall be interpreted consistently therewith. Limited Partnership Agreement of Cowtown Pipeline Partners L.P. Page 9 of 35
Minimum Gain Chargebacks. If there is a net decrease in the Partnership Minimum Gain or Partner Nonrecourse Debt Minimum Gain (determined in accordance with the principles of Treasury Regulations Sections 1.704-2(d) and 1.704-2(i)) during any Partnership taxable year, then items of income and gain for such year (and, if necessary, for subsequent periods) shall be allocated to the Partners in the manner and to the extent required by Treasury Regulations Section 1.704-2(f) and 1.704-2(i) (subject to the exceptions to this requirement described therein). This Section 4.8(c) is intended to constitute a “minimum gain chargeback” (both of Partnership Minimum Gain and of Partner Nonrecourse Debt Minimum Gain) as provided by Treasury Regulations Section 1.704-2(f), and this clause shall be construed accordingly.
Minimum Gain Chargebacks. (a) Notwithstanding anything to the contrary in Exhibit B Section 1, in the event that there is a net decrease in the Company Minimum Gain (as hereinafter defined) during a Company taxable year, each Member shall be allocated items of income and gain for such year (and, if necessary, subsequent years) in accordance with Section 1.704-1T(b)(4)(iv)(e) of the Regulations and its requirements for a "minimum gain chargeback."
