Common use of Partner Minimum Gain Chargeback Clause in Contracts

Partner Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(i)(4), if there is a net decrease in Partner Minimum Gain attributable to a Partner Nonrecourse Debt during any Partnership Year, each Partner who has a share of the Partner Minimum Gain attributable to such Partner Nonrecourse Debt, determined in accordance with Regulations Section 1.704-2(i)(5), shall be specially allocated items of Partnership income and gain for such year (and, if necessary, subsequent years) in an amount equal to such Holder’s share of the net decrease in Partner Minimum Gain attributable to such Partner Nonrecourse Debt, determined in a manner consistent with the provisions of Regulations Section 1.704-2(g)(2). This Section 6.3.C(ii) is intended to comply with the partner nonrecourse debt minimum gain chargeback requirement of Regulations Section 1.704-2(i)(4) and shall be interpreted consistently therewith.

Partner Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(i)(4), if If there is a net decrease in Partner Minimum Gain attributable to a Partner Nonrecourse Debt during any Partnership Yearfiscal year, each Partner who has a share of the Partner Minimum Gain attributable to such Partner Nonrecourse Recourse Debt, determined in accordance with Regulations Section 1.704-2(i)(5), shall be specially allocated items of Partnership income and gain for such fiscal year (and, if necessary, subsequent years) in an amount equal to such HolderPartner’s share of the net decrease in Partner Minimum Gain attributable to such Partner Nonrecourse Debt, determined in a manner consistent with the provisions of Regulations Section 1.704-2(g)(2). This Section 6.3.C(ii) 5.4.2 is intended to comply with the partner nonrecourse debt minimum gain chargeback requirement of Regulations Section 1.704-2(i)(4) and shall be interpreted consistently therewith.

Partner Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(i)(4), if If there is a net decrease in Partner Nonrecourse Debt Minimum Gain attributable to a Partner Nonrecourse Debt during any Partnership Yearyear, each Partner who has a share of the that Partner Nonrecourse Debt Minimum Gain attributable as of the beginning of the Fiscal Period shall, to such Partner Nonrecourse Debt, determined in accordance with Regulations the extent required by Section 1.704-2(i)(5)2(i)(4) of the Regulations, shall be specially allocated items of Partnership income and gain for such year (and, if necessary, subsequent years) in an amount equal to such Holderthat Partner’s share of the net decrease in Partner Nonrecourse Debt Minimum Gain attributable Gain. Allocations pursuant to such Partner Nonrecourse Debt, determined the previous sentence shall be made in a manner consistent accordance with the provisions of Regulations Section 1.704-2(g)(2)2(i)(4) of the Regulations. This Section 6.3.C(ii3.2(b) is intended to comply with the partner nonrecourse debt minimum gain chargeback requirement of Regulations in Section 1.704-2(i)(4) of the Regulations and shall be interpreted consistently therewith.

Partner Minimum Gain Chargeback. Except as otherwise provided in Regulations Notwithstanding any other provision of this Section 1.704-2(i)(4)5, if there is a net decrease in Partner Minimum Gain nonrecourse debt minimum gain attributable to a Partner Nonrecourse Debt nonrecourse debt (as defined in Treasury Regulations § 1.704-2(i)) during any Partnership Fiscal Year, each Partner who has a share of the Partner Minimum Gain attributable to such Partner Nonrecourse Debt, determined in accordance with Regulations Section 1.704-2(i)(5), shall be specially allocated items of Partnership income and gain for such year Fiscal Year (and, if necessary, subsequent yearsFiscal Years) in an amount equal to the portion of such HolderPartner’s share of the net decrease in Partner Minimum Gain nonrecourse debt minimum gain attributable to such Partner Nonrecourse DebtPartner’s nonrecourse debt, determined in a manner consistent accordance with the provisions of Treasury Regulations Section § 1.704-2(g)(22(i). This Section 6.3.C(ii5.2(c)(ii) is intended to comply with the partner nonrecourse debt minimum gain chargeback requirement in such section of the Treasury Regulations Section 1.704-2(i)(4) and shall be interpreted consistently therewith.

Partner Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(i)(4), if If there is a net decrease in Partner Nonrecourse Debt Minimum Gain attributable to a Partner Nonrecourse Debt during any Partnership Year, each Partner who has a share of the Partner Minimum Gain attributable to such Partner Nonrecourse Debt, determined partner nonrecourse debt (as defined in accordance with Treasury Regulations Section 1.704-2(i)(52(b)(4)) during any Fiscal Period, each Partner shall be specially allocated items of Partnership income and gain for such year Fiscal Period (and, if necessary, subsequent yearsFiscal Periods) in an amount equal to the portion of such Holder’s Partner's share of the net decrease in Partner Nonrecourse Debt Minimum Gain attributable to such Partner Nonrecourse DebtPartner's nonrecourse debt, as determined in a manner consistent accordance with the provisions of Treasury Regulations Section 1.704-2(g)(22(i). This Section 6.3.C(ii7.3(d)(ii) is intended to comply with the partner nonrecourse debt minimum gain chargeback requirement of requirements in such Treasury Regulations Section 1.704-2(i)(4) and shall be interpreted consistently therewith.

Partner Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(i)(4), if If there is a net decrease in Partner Minimum Gain attributable to a Partner Nonrecourse Debt during any Partnership Yearfiscal year, each Partner who has a share of the Partner Minimum Gain attributable to such Partner Nonrecourse Recourse Debt, determined in accordance with Regulations Section 1.704-2(i)(5), shall be specially allocated items of Partnership income and gain for such fiscal year (and, if necessary, subsequent years) in an amount equal to such HolderPartner’s share of the net decrease in Partner Minimum Gain attributable to such Partner Nonrecourse Debt, determined in a manner consistent with the provisions of Regulations Section 1.704-2(g)(22(i)(4). This Section 6.3.C(ii) 5.3.2 is intended to comply with the partner nonrecourse debt minimum gain chargeback requirement of Regulations Section 1.704-2(i)(4) and shall be interpreted consistently therewith.

Partner Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(i)(4), if If there is a net decrease in Partner Nonrecourse Debt Minimum Gain attributable to a Partner Nonrecourse Debt nonrecourse debt during any Partnership Fiscal Year, each such Partner who has a share of the Partner Nonrecourse Debt Minimum Gain attributable to such Partner Nonrecourse Debtdebt, determined in accordance with Regulations Section 1.704-2(i)(5), shall be specially allocated items of Partnership income and gain for such year Fiscal Year (and, if necessary, subsequent years) in an the amount equal to such Holder’s Partner's share of the net decrease in Partner Nonrecourse Debt Minimum Gain attributable to such Partner Nonrecourse Debtdebt, determined in a manner consistent with the provisions of Regulations Section 1.704-2(g)(2). This Section 6.3.C(ii4.4(c) is intended to comply with the partner nonrecourse debt minimum gain chargeback requirement of Regulations Section 1.704-2(i)(4) and shall be interpreted consistently therewith.