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

Partner Nonrecourse Debt Minimum Gain Chargeback. Notwithstanding any other provision of this Section 7.3 (other than Section 7.3(b) which shall be applied first), if there is a net decrease in Partner Nonrecourse Debt Minimum Gain with respect to a Partner Nonrecourse Debt during any taxable year or other period for which allocations are made, any Partner with a share of such Partner Nonrecourse Debt Minimum Gain (determined under Regulations Section 1.704-2(i)(5)) as of the beginning of the year will be specially allocated items of Partnership income and gain for that period (and, if necessary, subsequent periods) in an amount equal to such Partner’s share of the net decrease in the Partner Nonrecourse Debt Minimum Gain during such year determined in accordance with Regulations Section 1.704-2(g)(2). The items to be so allocated will be determined in accordance with Regulations Section 1.704-2(g). This Section 7.3(c) is intended to comply with the partner nonrecourse debt minimum gain chargeback requirements of the Regulations, will be interpreted consistently with the Regulations and will be subject to all exceptions provided therein.

Partner Nonrecourse Debt Minimum Gain Chargeback. Notwithstanding any other provision of this Section 7.3 9.3 (other than Section 7.3(b9.3(c)(1) which shall be applied first), if there is a net decrease in Partner Nonrecourse Debt Minimum Gain with respect to a Partner Nonrecourse Debt during any taxable year or other period for which allocations are were previously made, any Partner Member with a share of such Partner Nonrecourse Debt Minimum Gain (determined under Regulations Section 1.704-2(i)(5)) as of the beginning of the year will be specially allocated items of Partnership Company income and gain for that period (and, if necessary, subsequent periods) in an amount equal to such PartnerMember’s share of the net decrease in the Partner Nonrecourse Debt Minimum Gain during such year determined in accordance with Regulations Section 1.704-2(g)(2). The items to be so allocated will be determined in accordance with Regulations Section 1.704-2(g). This Section 7.3(c9.3(c)(2) is intended to comply with the partner nonrecourse debt minimum gain Partner Nonrecourse Debt Minimum Gain chargeback requirements of the Regulations, will be interpreted consistently with the Regulations and will be subject to all exceptions provided therein.

Partner Nonrecourse Debt Minimum Gain Chargeback. Notwithstanding any other provision provisions of this Section 7.3 (other than Section 7.3(b4.01.3(a) which shall be applied first), if there is a net decrease in Partner Nonrecourse Debt Minimum Gain with respect to a Partner Nonrecourse Debt during any taxable year or other period for which allocations are made, any Partner Member with a share of such Partner Nonrecourse Debt Minimum Gain attributable to any partner nonrecourse debt (determined under Treasury Regulations Section 1.704-2(i)(51.704-(2)(i)(5)) as of the beginning of the year will shall be specially allocated items of Partnership Company income and gain for that period (and, if necessary, subsequent periods) in an amount equal proportion to the portion of such PartnerMember’s share of the net decrease in the Partner Nonrecourse Debt Minimum Gain during with respect to such year determined in accordance with Regulations Section 1.704-2(g)(2)partner nonrecourse debt that is allocable to the disposition of Company property subject to such partner nonrecourse debt. The items to be so allocated will shall be determined in accordance with Treasury Regulations Section 1.704-2(g). This Section 7.3(c) is intended to comply with the partner nonrecourse debt minimum gain chargeback requirements of the Regulations, will Treasury Regulations and the exceptions thereto and shall be interpreted consistently with the Regulations and will be subject to all exceptions provided thereintherewith.

Partner Nonrecourse Debt Minimum Gain Chargeback. Notwithstanding any other provision of this Section 7.3 9.3 (other than Section 7.3(b9.3(c)(i) which shall be applied first), if there is a net decrease in Partner Nonrecourse Debt Minimum Gain with respect to a Partner Nonrecourse Debt during any taxable year or other period for which allocations are were previously made, any Partner Member with a share of such Partner Nonrecourse Debt Minimum Gain (determined under Regulations Section 1.704-2(i)(5)) as of the beginning of the year will be specially allocated items of Partnership Company income and gain for that period (and, if necessary, subsequent periods) in an amount equal to such PartnerMember’s share of the net decrease in the Partner Nonrecourse Debt Minimum Gain during such year determined in accordance with Regulations Section 1.704-2(g)(2). The items to be so allocated will be determined in accordance with Regulations Section 1.704l.704-2(g). This Section 7.3(c9.3(c)(ii) is intended to comply with the partner nonrecourse debt minimum gain Partner Nonrecourse Debt Minimum Gain chargeback requirements of the Regulations, will be interpreted consistently with the Regulations and will be subject to all exceptions provided therein.

Partner Nonrecourse Debt Minimum Gain Chargeback. Notwithstanding any other provision of this Section 7.3 9.3 (other than Section 7.3(b9.3(c)( 1) which shall be applied first), if there is a net decrease in Partner Nonrecourse Debt Minimum Gain with respect to a Partner Nonrecourse Debt during any taxable year or other period for which allocations are were previously made, any Partner Member with a share of such Partner Nonrecourse Debt Minimum Gain (determined under Regulations Section 1.704-2(i)(5)) as of the beginning of the year will be specially allocated items of Partnership Company income and gain for that period (and, if necessary, subsequent periods) in an amount equal to such PartnerMember’s share of the net decrease in the Partner Nonrecourse Debt Minimum Gain during such year determined in accordance with Regulations Section 1.704-2(g)(2). The items to be so allocated will be determined in accordance with Regulations Section 1.704-2(g). This Section 7.3(c9.3(c)(2) is intended to comply with the partner nonrecourse debt minimum gain Partner Nonrecourse Debt Minimum Gain chargeback requirements of the Regulations, will be interpreted consistently with the Regulations and will be subject to all exceptions provided therein.

Partner Nonrecourse Debt Minimum Gain Chargeback. Notwithstanding any other provision of this Section 7.3 (other than Section 7.3(b) which shall be applied first), if there is a net decrease in Partner Nonrecourse Debt Minimum Gain with respect to a Partner Nonrecourse Debt during any taxable year or other period for which allocations are made, any Partner with a share of such Partner Nonrecourse Debt Minimum Gain (determined under Regulations Section 1.704-2(i)(5)) as of the beginning of the year will be specially allocated items of Partnership income and gain for that period (and, if necessary, subsequent periods) in an amount equal to such Partner’s share of the net decrease in the Partner Nonrecourse Debt Minimum Gain during such year determined in accordance with Regulations Section 1.704-1.704- 2(g)(2). The items to be so allocated will be determined in accordance with Regulations Section 1.704-2(g). This Section 7.3(c) is intended to comply with the partner nonrecourse debt minimum gain chargeback requirements of the Regulations, will be interpreted consistently with the Regulations and will be subject to all exceptions provided therein.

Partner Nonrecourse Debt Minimum Gain Chargeback. Notwithstanding any other provision of this Section 7.3 16.4 (other than Section 7.3(b16.4(c)(1) which shall be applied first), if there is a net decrease in Partner Nonrecourse Debt Minimum Gain with respect to a Partner Nonrecourse Debt during any taxable year or other period for which allocations are made, any Partner Member with a share of such Partner Nonrecourse Debt Minimum Gain (determined under Regulations Section 1.704-2(i)(5)) as of the beginning of the year will be specially allocated items of Partnership Company income and gain for that period (and, if necessary, subsequent periods) in an amount equal to such PartnerMember’s share of the net decrease in the Partner Nonrecourse Debt Minimum Gain during such year determined in accordance with Regulations Section 1.704-2(g)(2). The items to be so allocated will be determined in accordance with Regulations Section 1.704-2(g). This Section 7.3(c16.4(c)(2) is intended to comply with the partner nonrecourse debt minimum gain Partner Nonrecourse Debt Minimum Gain chargeback requirements of the Regulations, will be interpreted consistently with the Regulations and will be subject to all exceptions provided therein.