Partner Nonrecourse Debt Minimum Gain Chargeback. Notwithstanding any other provision of this Article 5, except subsection 5.01(b)(i), if there is a net decrease in Partner Nonrecourse Debt Minimum Gain (as generally defined under Treas. Reg. § 1.704-1 or § 1.704-2), during any taxable year, any Partner who has a share of the Partner Nonrecourse Debt Minimum Gain shall be allocated such amount of income and gain for such year (and subsequent years, if necessary) determined in the manner required by Treas. Reg. § 1.704-2(i)(4) as is necessary to meet the requirements for a chargeback of Partner Nonrecourse Debt Minimum Gain.
Appears in 6 contracts
Samples: Duncan Energy Partners L.P., Duncan Energy Partners L.P., Duncan Energy Partners L.P.
Partner Nonrecourse Debt Minimum Gain Chargeback. Notwithstanding any other provision of this Article 54, except subsection 5.01(b)(i4.2(b)(i), if there is a net decrease in Partner Nonrecourse Debt Minimum Gain (as generally defined under Treas. Reg. § 1.704-1 or § 1.704-2), during any taxable year, any Partner who has a share of the Partner Nonrecourse Debt Minimum Gain shall be allocated such amount of income and gain for such year (and subsequent years, if necessary) determined in the manner required by Treas. Reg. § 1.704-2(i)(4) as is necessary to meet the requirements for a chargeback of Partner Nonrecourse Debt Minimum Gain.
Appears in 4 contracts
Samples: Agreement and Plan of Merger (Crestwood Midstream Partners LP), Agreement and Plan of Merger (Duncan Energy Partners L.P.), Oiltanking Partners, L.P.
Partner Nonrecourse Debt Minimum Gain Chargeback. Notwithstanding any other provision of this Article 5, except subsection 5.01(b)(iSection 5.2(c)(i), if there is a net decrease in Partner Nonrecourse Debt Minimum Gain (as generally defined under Treas. Reg. § Treasury Regulation §1.704-1 or § §1.704-2), during any taxable year, any Partner who has a share of the Partner Nonrecourse Debt Minimum Gain shall be allocated such amount of income and gain for such year (and subsequent years, if necessary) determined in the manner required by Treas. Reg. § Treasury Regulation §1.704-2(i)(4) as is necessary to meet the requirements for a chargeback of Partner Nonrecourse Debt Minimum Gain.
Appears in 3 contracts
Samples: General Partnership Agreement (El Paso Pipeline Partners, L.P.), General Partnership Agreement (El Paso Pipeline Partners, L.P.), General Partnership Agreement (El Paso Pipeline Partners, L.P.)
Partner Nonrecourse Debt Minimum Gain Chargeback. Notwithstanding any other provision of this Article 54, except subsection 5.01(b)(isubSection 4.2(b)(i), if there is a net decrease in Partner Nonrecourse Debt Minimum Gain (as generally defined under Treas. Reg. § 1.704-1 or § 1.704-2), during any taxable year, any Partner who has a share of the Partner Nonrecourse Debt Minimum Gain shall be allocated such amount of income and gain for such year (and subsequent years, if necessary) determined in the manner required by Treas. Reg. § 1.704-2(i)(4) as is necessary to meet the requirements for a chargeback of Partner Nonrecourse Debt Minimum Gain.
Appears in 1 contract
Samples: Agreement of Limited Partnership (Crestwood Midstream Partners LP)
Partner Nonrecourse Debt Minimum Gain Chargeback. Notwithstanding any other provision of this Article 5, except subsection 5.01(b)(iSection 5.2(c)(i), if there is a net decrease in Partner Nonrecourse Debt Minimum Gain (as generally defined under Treas. Reg. § Treasury Regulation §1.704-1 or § 1.704-2), during any taxable year, any Partner who has a share of the Partner Nonrecourse Debt Minimum Gain shall be allocated such amount of income and gain for such year (and subsequent years, if necessary) determined in the manner required by Treas. Reg. § Treasury Regulation §1.704-2(i)(4) as is necessary to meet the requirements for a chargeback of Partner Nonrecourse Debt Minimum Gain.
Appears in 1 contract
Samples: General Partnership Agreement (El Paso Pipeline Partners, L.P.)
