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 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 Notwithstanding any provision hereof to the contrary except Section 1.704-2(i)(45.3(c) (dealing with Minimum Gain), if there is a net decrease in Partner Nonrecourse Debt Minimum Gain attributable to for a Taxable Year (or if there was a net decrease in 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 for a prior Taxable Year and the Company did not have sufficient amounts of Partnership income and gain for such year (andduring prior years to allocate among the Partners under this Section 5.3(d)), if necessary, subsequent years) items of income and gain shall be allocated to each Partner in an amount equal to such HolderPartner’s share of the net decrease in Partner Nonrecourse Debt Minimum Gain attributable (as determined pursuant to such Partner Nonrecourse Debt, determined in a manner consistent with the provisions of Regulations Regulation Section 1.704-2(g)(22(i)(4)). This Section 6.3.C(ii5.3(d) is intended to comply with the constitute a partner nonrecourse debt minimum gain chargeback requirement of Regulations under Regulation 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.

Partner Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(i)(4)) of the Regulations, if in the event there is a net decrease in Partner Nonrecourse Debt Minimum Gain attributable to during a Partner Nonrecourse Debt during any Partnership Yeartaxable year, each Partner who has a share of the that Partner Nonrecourse Debt Minimum Gain attributable as of the beginning of the year, 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 Holder’s the Partner's share of the net decrease in Partner Nonrecourse Debt Minimum Gain attributable Gain. Allocations pursuant to such Partner Nonrecourse Debt, determined this Section 5.3(b) 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(ii5.3(b) is intended to comply with the partner nonrecourse debt minimum gain chargeback requirement of Regulations set forth 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 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)) of the Regulations, if in the event there is a net decrease in Partner Nonrecourse Debt Minimum Gain attributable to during a Partner Nonrecourse Debt during any Partnership Yeartaxable year, each Partner who has a share of the that Partner Nonrecourse Debt Minimum Gain attributable as of the beginning of the year, to such Partner Nonrecourse Debt, determined in accordance with Regulations the extent required by Regulation Section 1.704-2(i)(5), 2(i)(4) 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 the Partner's share of the net decrease in Partner Nonrecourse Debt Minimum Gain attributable Gain. Allocations pursuant to such Partner Nonrecourse Debt, determined this Section 5.3(b) shall be made in a manner consistent accordance with the provisions of Regulations Regulation Section 1.704-2(g)(22(i)(4). This Section 6.3.C(ii5.3(b) is intended to comply with the partner nonrecourse debt minimum gain chargeback requirement of Regulations set forth in Regulation 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)) of the Regulations, if in the event there is a net decrease in Partner Nonrecourse Debt Minimum Gain attributable to during a Partner Nonrecourse Debt during any Partnership Yeartaxable year, each Partner who has a share of the that Partner Nonrecourse Debt Minimum Gain attributable as of the beginning of the year, 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 Holderthe Partner’s share of the net decrease in Partner Nonrecourse Debt Minimum Gain attributable Gain. Allocations pursuant to such Partner Nonrecourse Debt, determined this Section 5.3(b) 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(ii5.3(b) is intended to comply with the partner nonrecourse debt minimum gain chargeback requirement of Regulations set forth 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 provision hereof to the contrary except Section 1.704-2(i)(45.2(c) (dealing with Minimum Gain), if there is a net decrease in Partner Nonrecourse Debt Minimum Gain attributable to for a Taxable Year (or if there was a net decrease in 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 for a prior Taxable Year and the Company did not have sufficient amounts of Partnership income and gain for such year (andduring prior years to allocate among the Partners under this Section 5.2(d)), if necessary, subsequent years) items of income and gain shall be allocated to each Partner in an amount equal to such HolderPartner’s share of the net decrease in Partner Nonrecourse Debt Minimum Gain attributable (as determined pursuant to such Partner Nonrecourse Debt, determined in a manner consistent with the provisions of Regulations Regulation Section 1.704-2(g)(22(i)(4)). This Section 6.3.C(ii5.2(d) is intended to comply with the constitute a partner nonrecourse debt minimum gain chargeback requirement of Regulations under Regulation Section 1.704-2(i)(4) and shall be interpreted consistently therewith.