Common use of Partner Nonrecourse Deductions and Chargebacks Clause in Contracts

Partner Nonrecourse Deductions and Chargebacks. Notwithstanding any other provision of this Agreement to the contrary, any partner nonrecourse deductions (as defined in Treasury Regulations § 1.704-2(i)(1)) shall be allocated to the Partner who (in his, her or its capacity, directly or indirectly, as lender, guarantor, or otherwise) bears the economic risk of loss with respect to the loan to which such partner nonrecourse deductions are attributable in accordance with Treasury Regulations § 1.704-2(i). Notwithstanding any other provision of this Agreement, if during a taxable year of the Partnership there is a net decrease in partner nonrecourse debt minimum gain, as that term is defined in Treasury Regulations § 1.704-2(i)(2), that decrease shall be charged back among the Partners in accordance with Treasury Regulations § 1.704-2(i)(4). The preceding sentence is intended to comply with the partner nonrecourse debt minimum gain chargeback requirement of Treasury Regulations § 1.704-2(i)(4) and shall be interpreted and applied in a manner consistent therewith.

Partner Nonrecourse Deductions and Chargebacks. Notwithstanding any other provision of this Agreement to the contrary, any partner nonrecourse deductions (as defined in Treasury Regulations § 1.704-2(i)(12(i)(l)) shall be allocated to the Partner who (in his, her or its capacity, directly or indirectly, as lender, guarantor, or otherwise) bears the economic risk of loss with respect to the loan to which such partner nonrecourse deductions are attributable in accordance with Treasury Regulations § 1.704-2(i). Notwithstanding any other provision of this Agreement, if during a taxable year of the Partnership there is a net decrease in partner nonrecourse debt minimum gain, as that term is defined in Treasury Regulations § 1.704-2(i)(2), that decrease shall be charged back among the Partners in accordance with Treasury Regulations § 1.704-2(i)(4). The preceding sentence is intended to comply with the partner nonrecourse debt minimum gain chargeback requirement of Treasury Regulations § 1.704-2(i)(4) and shall be interpreted and applied in a manner consistent therewith.

Partner Nonrecourse Deductions and Chargebacks. Notwithstanding any other provision of this Agreement to the contrary, any partner nonrecourse deductions (as defined in Treasury Regulations § Section 1.704-2(i)(1)) shall be allocated to the Partner who (in his, her or its capacity, directly or indirectly, as lender, guarantor, guarantor or otherwise) bears the economic risk of loss with respect to the loan to which such partner nonrecourse deductions are attributable in accordance with Treasury Regulations § Section 1.704-2(i). Notwithstanding any other provision of this Agreement, if during a taxable year of the Partnership there is a net decrease in partner nonrecourse debt minimum gain, gain (as that term is defined in Treasury Regulations § Section 1.704-2(i)(2)), that decrease shall be charged back among the Partners in accordance with Treasury Regulations § Section 1.704-2(i)(4). The preceding sentence is intended to comply with the partner nonrecourse debt minimum gain chargeback requirement of Treasury Regulations § 1.704-Section 1.704- 2(i)(4) and shall be interpreted and applied in a manner consistent therewith.