Common use of Partner Nonrecourse Debt Minimum Gain Chargeback Clause in Contracts

Partner Nonrecourse Debt Minimum Gain Chargeback. If there is a net decrease in Partner Nonrecourse Debt Minimum Gain during a Fiscal Year or other period, then each Member shall be allocated items of Company gross income or gain equal to such Member’s share of such net decrease, except to the extent such allocation would not be required under Section l.704-2(i)(4) or 1.704-2(j)(2) of the Treasury Regulations. The amounts referred to in this Section 6.4(b)(iv) and the items to be so allocated shall be determined in accordance with Section 1.704-2 of the Treasury Regulations. This Section 6.4(b)(iv) is intended to comply with the minimum gain chargeback requirement contained in Section 1.704-2(i)(4) of the Treasury Regulations and shall be interpreted consistently therewith.

Partner Nonrecourse Debt Minimum Gain Chargeback. If there is a net decrease in Partner Nonrecourse Debt Minimum Gain during a Fiscal Year or other period, then each Member shall be allocated items of Company gross income or gain equal to such Member’s 's share of such net decrease, except to the extent such allocation would not be required under Treasury Regulation Section l.7041.704-2(i)(4) or 1.704-2(j)(2) of the Treasury Regulations). The amounts referred to in this Section 6.4(b)(iv6.3(b)(iv) and the items to be so allocated shall be determined in accordance with Treasury Regulation Section 1.704-2 of the Treasury Regulations2. This Section 6.4(b)(iv6.3(b)(iv) is intended to comply with the minimum gain chargeback requirement contained in Treasury Regulation Section 1.704-2(i)(4) of the Treasury Regulations and shall be interpreted consistently therewith.

Partner Nonrecourse Debt Minimum Gain Chargeback. If there is a net decrease in Partner Nonrecourse Debt Minimum Gain during a Fiscal Year or other period, then each Member shall be allocated items of Company gross income or gain equal to such Member’s share of such net decrease, except to the extent such allocation would not be required under Treasury Regulation Section l.7041.704-2(i)(4) or 1.704-2(j)(2) of the Treasury Regulations). The amounts referred to in this Section 6.4(b)(iv6.3(b)(iv) and the items to be so allocated shall be determined in accordance with Treasury Regulation Section 1.704-2 of the Treasury Regulations2. This Section 6.4(b)(iv6.3(b)(iv) is intended to comply with the minimum gain chargeback requirement contained in Treasury Regulation Section 1.704-2(i)(4) of the Treasury Regulations and shall be interpreted consistently therewith.

Partner Nonrecourse Debt Minimum Gain Chargeback. If there is a net decrease in Partner Nonrecourse Debt Minimum Gain during a Fiscal Year Partnership fiscal year or other period, then each Member Partner shall be allocated items of Company gross Partnership income and gain for such fiscal year or gain other period (and, if necessary, for subsequent fiscal years or periods) equal to such Member’s Partner's share of such net decrease, except to the extent such allocation would not be required under by Regulations Section l.7041.704-2(i)(4) or 1.704-2(j)(2) of the Treasury Regulations). The amounts referred to in this Section 6.4(b)(iv4.7(d) and the items to be so allocated shall be determined in accordance with Regulations Section 1.704-2 of the Treasury Regulations2. This Section 6.4(b)(iv4.7(d) is intended to comply with the minimum gain chargeback requirement contained in Regulations Section 1.704-2(i)(4) of the Treasury Regulations ), and shall be interpreted consistently therewith.