Common use of Partner Minimum Gain Chargeback Clause in Contracts

Partner Minimum Gain Chargeback. If there is a net decrease in Partner Nonrecourse Debt Minimum Gain during any year, each Partner who has a share of that Partner Nonrecourse Debt Minimum Gain as of the beginning of the Fiscal Period shall, to the extent required by Section 1.704-2(i)(4) of the Regulations, be specially allocated items of Partnership income and gain for such year (and, if necessary, subsequent years) equal to that Partner’s share of the net decrease in Partner Nonrecourse Debt Minimum Gain. Allocations pursuant to the previous sentence shall be made in accordance with Section 1.704-2(i)(4) of the Regulations. This Section 3.2(b) is intended to comply with the requirement in Section 1.704-2(i)(4) of the Regulations and shall be interpreted consistently therewith.

Partner Minimum Gain Chargeback. If there is a net decrease in Partner Nonrecourse Debt Minimum Gain “partner nonrecourse debt minimum gain” (as that term is defined in Sections 1.704-2(i)(2) and (3) of the Regulations) during any yearFiscal Year, each Partner who has a share of that Partner Nonrecourse Debt Minimum Gain partner nonrecourse debt minimum gain as of the beginning of the Fiscal Period Year shall, to the extent required by Section 1.704-2(i)(4) of the Regulations, be specially allocated items of Partnership income and gain for such year Fiscal Year (and, if necessary, subsequent yearsFiscal Years) equal to that Partner’s share of the net decrease in Partner Nonrecourse Debt Minimum Gainpartner nonrecourse debt minimum gain. Allocations pursuant to the previous sentence shall be made in accordance with Section 1.704-2(i)(4) of the Regulations. This Section 3.2(b5.05(b) is intended to comply with the requirement in Section 1.704-2(i)(4) of the Regulations and shall be interpreted consistently therewith.

Partner Minimum Gain Chargeback. If Notwithstanding Section 4.1, if there is a net decrease in Partner Nonrecourse Debt Minimum Gain nonrecourse debt minimum gain (as defined in Regulation § 1.704-2(i)(2)) during any Partnership taxable year, each Partner who has with a share of that Partner Nonrecourse Debt Minimum Gain nonrecourse debt minimum gain (determined under Regulation § 1.704-2(i)(5)) as of the beginning of the Fiscal Period shallyear shall be specifically allocated, to the extent required by Section 1.704-2(i)(4) of the Regulationsbefore any other allocation is made, be specially allocated items of Partnership income and gain for such year (and, and if necessary, subsequent years) equal to that Partner’s share of the net decrease in Partner Nonrecourse Debt Minimum Gainthe Partner’s nonrecourse debt minimum gain. Allocations pursuant to the previous sentence shall be made in accordance with Section proportion to the respective amounts required to be allocated to the Partners. This provision shall be applied so that it will constitute a “chargeback of Partner nonrecourse debt minimum gain” as prescribed by Regulation § 1.704-2(i)(4) of the Regulations. This Section 3.2(b) is intended to comply with the requirement in Section 1.704-2(i)(4) of the Regulations and shall be interpreted consistently therewith).

Partner Minimum Gain Chargeback. If there is a net decrease in Partner Nonrecourse Debt Minimum Gain “partner nonrecourse debt minimum gain” (as that term is defined in Sections 1.704-2(i)(2) and (3) of the Regulations) during any year, each Partner who has a share of that Partner Nonrecourse Debt Minimum Gain partner nonrecourse debt minimum gain as of the beginning of the Fiscal Period Year shall, to the extent required by Section 1.704-2(i)(4) of the Regulations, be specially allocated items of Partnership income and gain for such year (and, if necessary, subsequent years) equal to that Partner’s share of the net decrease in Partner Nonrecourse Debt Minimum Gainpartner nonrecourse debt minimum gain. Allocations pursuant to the previous sentence shall be made in accordance with Section 1.704-2(i)(4) of the Regulations. This Section 3.2(b) is intended to comply with the requirement in Section 1.704-2(i)(4) of the Regulations and shall be interpreted consistently therewith.

Partner Minimum Gain Chargeback. If Notwithstanding Section 4.1, if there is a net decrease in Partner Nonrecourse Debt Minimum Gain nonrecourse debt minimum gain (as defined in Regulation §1.704-2(i)(2)) during any Partnership taxable year, ; each Partner who has with a share of that Partner Nonrecourse Debt Minimum Gain nonrecourse debt minimum gain (determined under Regulation §1.704-2(i)(5)) as of the beginning of the Fiscal Period shallyear shall be specifically allocated, to the extent required by Section 1.704-2(i)(4) of the Regulationsbefore any other allocation is made, be specially allocated items of Partnership income and gain for such year (and, if necessary, subsequent years) equal to that Partner’s share of the net decrease in Partner Nonrecourse Debt Minimum Gainthe Partner’s nonrecourse debt minimum gain. Allocations pursuant to the previous sentence shall be made in accordance with Section proportion to the respective amounts required to be allocated to the Partners. This provision shall be applied so that it will constitute a “chargeback of Partner nonrecourse debt minimum gain” as prescribed by Regulation §1.704-2(i)(4) of the Regulations. This Section 3.2(b) is intended to comply with the requirement in Section 1.704-2(i)(4) of the Regulations and shall be interpreted consistently therewith).

Partner Minimum Gain Chargeback. If there is a net decrease in Partner Nonrecourse Debt Minimum Gain "partner nonrecourse debt minimum gain" (as that term is defined in Sections 1.704-2(i)(2) and (3) of the Regulations) during any year, each Partner Venturer who has a share of that Partner Nonrecourse Debt Minimum Gain partner nonrecourse debt minimum gain as of the beginning of the Fiscal Period year shall, to the extent required by Section 1.704-2(i)(4) of the Regulations, be specially allocated items of Partnership Venture income and gain for such year (and, if necessary, subsequent years) equal to that Partner’s Venturer's share of the net decrease in Partner Nonrecourse Debt Minimum Gainpartner nonrecourse debt minimum gain. Allocations pursuant to the previous sentence shall be made in accordance with Section 1.704-2(i)(4) of the Regulations. This Section 3.2(b4.06(d)(ii) is intended to comply with the requirement in Section 1.704-2(i)(4) of the Regulations and shall be interpreted consistently therewith.