Common use of Partner Non-recourse Debt Minimum Gain Chargeback Clause in Contracts

Partner Non-recourse Debt Minimum Gain Chargeback. If there is a net decrease in Minimum Gain attributable to partner non-recourse debt (determined pursuant to Treasury Regulations Section 1.704-2(i)) during any Fiscal Year, certain items of income and gain, including gross income or gain, shall be allocated as quickly as possible to those Members which had a share of the Minimum Gain attributable to the partner non-recourse debt (such share determined pursuant to Treasury Regulations Section 1.704-1(i)(5)) in the amounts and manner described in Treasury Regulations Section 1.704-2(i) and (j). This Section 7.2(b) is intended to comply with the minimum gain chargeback requirement relating to partner non-recourse debt set forth in Treasury Regulations Section 1.704-2(i)(4)) and shall be so interpreted.

Partner Non-recourse Debt Minimum Gain Chargeback. If there is a net decrease in Minimum Gain attributable to partner non-recourse debt (determined pursuant to Treasury Regulations Section ss. 1.704-2(i)) during any Fiscal Year, certain items of income and gain, including gross income or gain, shall be allocated as quickly as possible to those Members Limited Partners which had a share of the Minimum Gain attributable to the partner non-recourse debt (such share determined pursuant to Treasury Regulations Section ss. 1.704-1(i)(5)) in the amounts and manner described in Treasury Regulations Section ss. 1.704-2(i) and (j). This Section 7.2(b) is intended to comply with the minimum gain chargeback requirement relating to partner non-recourse debt set forth in Treasury Regulations Section 1.704ss. 1. 704-2(i)(4)) and shall be so interpreted.

Partner Non-recourse Debt Minimum Gain Chargeback. If there is a net decrease in Minimum Gain attributable to partner non-recourse debt (determined pursuant to Treasury Regulations Section ss. 1.704-2(i)) during any Fiscal Year, certain items of income and gain, including gross income or gain, shall be allocated as quickly as possible to those Members Limited Partners which had a share of the Minimum Gain attributable to the partner non-recourse debt (such share determined pursuant to Treasury Regulations Section ss. 1.704-1(i)(5)) in the amounts and manner described in Treasury Regulations Section ss. 1.704-2(i) and (j). This Section 7.2(b) is intended to comply with the minimum gain chargeback requirement relating to partner non-recourse debt set forth in Treasury Regulations Section ss. 1.704-2(i)(4)) and shall be so interpreted.

Partner Non-recourse Debt Minimum Gain Chargeback. If there is a net decrease in Minimum Gain attributable to partner non-recourse debt (determined pursuant to Treasury Regulations Section ss. 1.704-2(i)) during any Fiscal Year, certain items of income and gain, including gross income or gain, shall be allocated allocateD as quickly as possible to those Members Limited Partners which had a share of the Minimum Gain attributable to the partner non-recourse debt (such share determined pursuant to Treasury Regulations Section ss. 1.704-1(i)(5)) in the amounts and manner described in Treasury Regulations Section ss. 1.704-2(i) and (j). This Section 7.2(b) is intended to comply with the minimum gain chargeback requirement relating to partner non-recourse debt set forth in Treasury Regulations Section 1.704ss. 1. 704-2(i)(4)) and anD shall be so interpreted.