Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 6.1(d)(vi) and Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 117 contracts

Samples: Agreement, Fourth (Summit Midstream Partners, LP), Partnership Interests Restructuring Agreement (Shell Midstream Partners, L.P.)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to ~~Section~~ Sections 6.1(d)(vi) and ~~Section~~ 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 43 contracts

Samples: Partnership Agreement (Stonemor Partners Lp), Equity Restructuring Agreement (HollyFrontier Corp), Equity Restructuring Agreement (Holly Energy Partners Lp)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or and gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(d)(iii) and ~~Section 6.1(d)(vii~~6.1(d)(vi)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 24 contracts

Samples: Agreement and Plan of Merger (Och-Ziff Capital Management Group LLC), Letter Agreement (Och-Ziff Capital Management Group LLC), Letter Agreement (Och-Ziff Capital Management Group LLC)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of gross income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 6.1(d)(vi) and Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 19 contracts

Samples: Contribution and Simplification Agreement (Noble Midstream Partners LP), Transaction Agreement (Hess Midstream Partners LP), Contribution Agreement and Agreement (Anadarko Petroleum Corp)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 6.1(d)(v) and ~~Section 6.1(d)(vii~~6.1(d)(vi)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 13 contracts

Samples: Energy Transfer LP, Energy Transfer LP, Agreement and Plan of Merger (Southern Union Co)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section ~~6.1~~5.01, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in ~~Treasury~~ Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~5.01(b), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~5.01(b) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 5.01(b)(vi) and ~~Section 6.1(d)(vii~~5.01(b)(vii)). This Section ~~6.1(d)(i~~5.01(b)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in ~~Treasury~~ Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 12 contracts

Samples: Agreement (Enterprise Products Partners L P), Enterprise Products Partners L P, Williams Randa Duncan

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections ~~1.704-~~1.704- 2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 6.1(d)(vi) and Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 11 contracts

Samples: Andeavor Logistics Lp, Tesoro Logistics Lp, www.lw.com

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(b), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(b) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 6.1(b)(vi) and ~~Section 6.1(d)(vii~~6.1(b)(vii)). This Section ~~6.1(d)(i~~6.1(b)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 10 contracts

Samples: CVR Partners, Lp, Agreement, Management and Operation of Business (PetroLogistics LP)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 6.1(d)(vi) ~~and~~ or Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 8 contracts

Samples: CDM Contribution Agreement (USA Compression Partners, LP), Contribution Agreement (Energy Transfer Partners, L.P.), Registration Rights Agreement (USA Compression Partners, LP)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-~~2(f)(6~~2(f), 1.704-~~2(g)(2~~2(g) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(b), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(b) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(b)(v) and Section ~~6.1(d)(vii~~6.1(b)(vi)). This Section ~~6.1(d)(i~~6.1(b)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 6 contracts

Samples: Management Services Agreement (Nextera Energy Partners, Lp), NextEra Energy Partners, LP, NextEra Energy Partners, LP

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(c), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(c) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 6.1(c)(vi) and ~~Section 6.1(d)(vii~~6.1(c)(vii)). This Section ~~6.1(d)(i~~6.1(c)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 6 contracts

Samples: Enterprise Products Partners L.P., NuStar Energy L.P., Agreement

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(d)(vii) and Section ~~6.1(d)(vii~~6.1(d)(viii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 5 contracts

Samples: Partnership Interests Exchange Agreement (Western Midstream Partners, LP), Exchange Agreement (Western Midstream Partners, LP), Fourth (Cheniere Energy Partners, L.P.)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(c)(i), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(c)(i) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(c)(v) and Section ~~6.1(d)(vii~~6.1(c)(vi)). This Section ~~6.1(d)(i~~6.1(c)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 4 contracts

Samples: Agreement and Plan of Merger (Inergy Holdings, L.P.), Agreement and Plan of Merger (Inergy L P), Inergy L P

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor ~~provision~~provisions. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 6.1(d)(vi) and Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 4 contracts

Samples: Sprague Resources LP, Sprague Resources LP, Sprague Resources LP

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(c), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(c) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(c)(vi) and Section ~~6.1(d)(vii~~6.1(c)(vii)). This Section ~~6.1(d)(i~~6.1(c)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 4 contracts

Samples: CSI Compressco LP, Legacy Reserves Lp, Legacy Reserves Lp

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(e), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or and gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(e) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(e)(iii) and ~~Section 6.1(d)(vii~~6.1(e)(vi)). This Section ~~6.1(d)(i~~6.1(e)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 4 contracts

Samples: Och-Ziff Capital Management Group LLC, Och-Ziff Capital Management Group LLC, Och-Ziff Capital Management Group LLC

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 6.1(d)(vi) and Section ~~6.1(d)(vii~~6.1 (d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 4 contracts

Samples: Dissolution and Liquidation (Williams Partners L.P.), Dissolution and Liquidation (Williams Partners L.P.), Williams Partners L.P.

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(b), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(b) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 6.1(b)(v) and ~~Section 6.1(d)(vii~~6.1(b)(vi)). This Section ~~6.1(d)(i~~6.1(b)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 4 contracts

Samples: Article Xiv Merger (Enterprise GP Holdings L.P.), Contribution and Assumption Agreement (Magellan Midstream Partners Lp), Simplification Agreement (Magellan Midstream Partners Lp)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(d)(i), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(d)(v) and Section ~~6.1(d)(vii~~6.1(d)(vi)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 4 contracts

Samples: Amended and Restated Agreement (Harbinger Group Inc.), Agreement (Harbinger Group Inc.), Agreement (Exco Resources Inc)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership gross income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of gross income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 6.1(d)(vi) ~~and~~ or Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 4 contracts

Samples: Sharing Agreement (Phillips 66 Partners Lp), Partnership Interests Restructuring Agreement (Phillips 66), Sharing Agreement (Phillips 66 Partners Lp)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i)~~, or any successor provision~~. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to ~~Section~~ Sections 6.1(d)(vi) and ~~Section~~ 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 4 contracts

Samples: Tc Pipelines Lp, Tc Pipelines Lp, Tc Pipelines Lp

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(c), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or and gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(c) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(c)(iii) and ~~Section 6.1(d)(vii~~6.1(c)(vi)). This Section ~~6.1(d)(i~~6.1(c)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 4 contracts

Samples: Och-Ziff Capital Management Group LLC, Och-Ziff Capital Management Group LLC, Och-Ziff Capital Management Group LLC

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(d)(i), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(d)(i) with respect to such taxable period (other than an allocation pursuant to Section 6.1(d)(vi) and Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 3 contracts

Samples: www.lw.com, Crestwood Equity Partners LP, Inergy L P

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section ~~6.1~~5.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~5.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~5.1(d) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 5.1(d)(vi) and ~~Section 6.1(d)(vii~~5.1(d)(vii)). This Section ~~6.1(d)(i~~5.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 3 contracts

Samples: Star Gas Partners Lp, Star Gas Partners Lp, ONEOK Partners LP

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(c), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of gross income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(c) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(c)(vi) and Section ~~6.1(d)(vii~~6.1(c)(vii)). This Section ~~6.1(d)(i~~6.1(c)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 3 contracts

Samples: Contribution and Simplification Agreement (Oasis Midstream Partners LP), Contribution and Simplification Agreement (Oasis Petroleum Inc.), Contribution and Simplification Agreement (Oasis Midstream Partners LP)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 6.1(d)(vi) and Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-~~2(f~~2 (f) and shall be interpreted consistently therewith.

Appears in 3 contracts

Samples: www.lw.com, www.lw.com, www.lw.com

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership gross income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of gross income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 6.1(d)(vi) and Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 3 contracts

Samples: Midcoast Energy Partners, L.P., Phillips 66 Partners Lp, www.lw.com

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-~~2(f)(6~~2(f), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to ~~Section~~ Sections 6.1(d)(vi) and ~~Section~~ 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 3 contracts

Samples: CVR Energy Inc, CVR Energy Inc, CVR Energy Inc

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(c), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(c) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 6.1(c)(v) and ~~Section 6.1(d)(vii~~6.1(c)(vi)). This Section ~~6.1(d)(i~~6.1(c)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 3 contracts

Samples: Administrative Services Agreement (Duncan Energy Partners L.P.), Suburban Propane Partners Lp, Suburban Propane Partners Lp

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), 55 or any successor provision. For purposes of this Section ~~6.1(d~~6.1(c), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(c) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 6.1(c)(vi) and ~~Section 6.1(d)(vii~~6.1(c)(vii)). This Section ~~6.1(d)(i~~6.1(c)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 2 contracts

Samples: Preferred Unit Purchase Agreement (Natural Resource Partners Lp), Preferred Unit Purchase Agreement

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section ~~6.1~~5.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~5.1(c), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~5.1(c) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 5.1(c)(v) and ~~Section 6.1(d)(vii~~5.1(c)(vi)). This Section ~~6.1(d)(i~~5.1(c)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 2 contracts

Samples: Agreement, Agreement (Kinder Morgan Energy Partners L P)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this ~~Section~~ ‎Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this ~~Section~~ ‎Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this ~~Section~~ ‎Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to ~~Section~~ ‎Section 6.1(d)(vi) and ~~Section~~ ‎Section 6.1(d)(vii)). This ~~Section~~ ‎Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 2 contracts

Samples: Exchange Agreement (Delek Logistics Partners, LP), Exchange Agreement (Delek US Holdings, Inc.)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s 's Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 6.1(d)(vi) and Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 2 contracts

Samples: Unit Purchase Agreement (Cheniere Energy Partners, L.P.), Cheniere Energy Partners, L.P.

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section ~~6.1~~5.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-~~2(f)(6~~2(f)(b), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~5.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~5.1(d) with respect to such taxable ~~period (other than an allocation pursuant to Section 6.1(d)(vi) and Section 6.1(d)(vii))~~period. This Section ~~6.1(d)(i~~5.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 2 contracts

Samples: Terra Nitrogen Co L P /De, Terra Nitrogen Co L P /De

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any ~~Partnership~~ Company taxable period, each ~~Partner~~ Member shall be allocated items of ~~Partnership~~ Company income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury ~~Regulation~~ Regulations Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d)~~6.1.3, each ~~Partner’s~~ Member's Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d)~~ 6.1.3 with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi)~~ Sections 6.1.3.5 and ~~Section 6.1(d)(vii)~~6.1.3.6). This Section ~~6.1(d)(i)~~ 6.1.3.1 is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury ~~Regulation~~ Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 2 contracts

Samples: Operating Agreement (U S Timberlands Co Lp), Operating Agreement (U S Timberlands Klamath Falls LLC)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(c)(i), each Partner’s 's Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(c)(i) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(c)(v) and Section ~~6.1(d)(vii~~6.1(c)(vi)). This Section ~~6.1(d)(i~~6.1(c)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 2 contracts

Samples: Agreement and Plan of Redemption and Merger (Markwest Energy Partners L P), Agreement and Plan of Redemption and Merger (Markwest Hydrocarbon Inc)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(e), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(e) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(e)(vi) and Section ~~6.1(d)(vii~~6.1(e)(vii)). This Section ~~6.1(d)(i~~6.1(e)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 2 contracts

Samples: Securities Purchase and Global Transaction Agreement (Eagle Rock Energy Partners L P), Securities Purchase and Global Transaction Agreement (Eagle Rock Energy Partners L P)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section ~~6.1~~5.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury ~~Regulation~~ Regulations Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i)~~, or any successor provision~~. For purposes of this Section ~~6.1(d~~5.1(b), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~5.1(b) with respect to such taxable period (other than ~~an allocation~~ allocations pursuant to ~~Section 6.1(d)(vi~~Sections 5.1(b)(v) and ~~Section 6.1(d)(vii~~5.1(b)(vi)). This Section ~~6.1(d)(i~~5.1(b)(i) is intended to comply with the ~~Partnership Minimum Gain chargeback~~ “partnership minimum gain chargeback” requirement in Treasury ~~Regulation~~ Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 2 contracts

Samples: Limited Partnership Agreement (Athlon Energy Inc.), Limited Partnership Agreement (Athlon Energy Inc.)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section ~~6.1~~5.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d)~~5.1.4.1, each Partner’s 's Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d)~~ 5.1.4 with respect to such taxable ~~period (other than an allocation pursuant to Section 6.1(d)(vi) and Section 6.1(d)(vii))~~period. This Section ~~6.1(d)(i)~~ 5.1.4.1 is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.;

Appears in 2 contracts

Samples: Kaneb Pipe Line Partners L P, Kaneb Pipe Line Partners L P

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections ~~1.704-~~1.704- 2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(c), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(c) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(c)(v) and Section ~~6.1(d)(vii~~6.1(c)(vi)). This Section ~~6.1(d)(i~~6.1(c)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 2 contracts

Samples: First (EQT GP Holdings, LP), EQGP Holdings, LP

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section ~~6.1~~5.2, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~5.2(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~5.2(d) with respect to such ~~taxable period~~ Tax Year (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 5.2(d)(v) and ~~Section 6.1(d)(vii~~5.2(d)(vi)). This Section ~~6.1(d)(i~~5.2(d)(i) is intended to comply with the Partnership Minimum Gain ~~chargeback~~ Chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 2 contracts

Samples: Original Agreement (Energy Transfer Partners, L.P.), Original Agreement (Energy Transfer Equity, L.P.)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s 's Adjusted Capital Account balance shall be determined, and the allocation of income or and gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(d)(iii) and ~~Section 6.1(d)(vii~~6.1(d)(vi)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 2 contracts

Samples: Och Daniel, Och Daniel

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), ~~1.704-2(g)(2~~1.7042(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 6.1(d)(vi) and Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 2 contracts

Samples: Assignment and Assumption Agreement (USD Partners LP), USD Partners LP

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(b), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(b)(i) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 6.1(b)(v) and ~~Section 6.1(d)(vii~~6.1(b)(vi)). This Section ~~6.1(d)(i~~6.1(b)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 2 contracts

Samples: Agreement and Plan of Merger (Penn Virginia GP Holdings, L.P.), Penn Virginia Resource Partners L P

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(c), each Partner’s 's Adjusted Capital Account balance shall be determined, and the allocation of income or and gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(c) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(c)(iii) and ~~Section 6.1(d)(vii~~6.1(c)(vi)). This Section ~~6.1(d)(i~~6.1(c)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Och Daniel

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section ~~6.1~~5.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~5.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~5.1(d) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 5.1(d)(vi) and ~~Section 6.1(d)(vii~~5.1(d)(vii)). This Section ~~6.1(d)(i~~5.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section ~~1.704-2(f~~1.704‑2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Ferrellgas Partners Finance Corp

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section ~~6.1~~5.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~5.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~5.1(d) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~5.1(d)(vi) and Section ~~6.1(d)(vii~~5.1(d)(vii)). This Section ~~6.1(d)(i~~5.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: El Paso Pipeline Partners, L.P.

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any ~~Partnership~~ Company taxable period, each ~~Partner~~ Member shall be allocated items of ~~Partnership~~ Company income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each ~~Partner~~Member’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 6.1(d)(v) and ~~Section 6.1(d)(vii~~6.1(d)(vi)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Company Agreement (Enterprise Products Partners L P)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section ~~6.1~~5.2, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in U.S. Treasury ~~Regulation~~ Regulations Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~4.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or and gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~5.2(b) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 5.2(b)(iii) and ~~Section 6.1(d)(vii)~~(vi). This Section ~~6.1(d)(i~~5.2(b)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in U.S. Treasury ~~Regulation~~ Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Voting Agreement (Burger King Worldwide, Inc.)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s 's Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 6.1(d)(vi) ~~and~~ or Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Agreement (Dominion Midstream Partners, LP)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), ~~1.704-~~1.704- 2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 6.1(d)(vi) and Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: www.envivabiomass.com

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and ~~1.704-~~1.704- 2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(d)(vii) and Section ~~6.1(d)(vii~~6.1(d)(viii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Agreement

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury ~~Regulation~~ Regulations Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 6.1(d)(vi) and Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury ~~Regulation~~ Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Partnership Agreement (CrossAmerica Partners LP)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) ), with respect to such taxable period (other than an allocation pursuant to Section 6.1(d)(vi) and Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Targa Resources Partners LP

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to 55 such taxable period (other than an allocation pursuant to Section 6.1(d)(vi) and Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Williams Pipeline Partners L.P.

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(c), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(c) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 6.1(c)(vi) and ~~Section 6.1(d)(vii~~6.1(c)(vii)). This Section ~~6.1(d)(i~~6.1(c)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-~~2(f~~2 (f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Agreement

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership gross income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(b), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of gross income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(b) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(b)(vi) and Section ~~6.1(d)(vii~~6.1(b)(vii)). This Section ~~6.1(d)(i~~6.1(b)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: OCI Partners LP

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section ~~6.1~~5.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and ~~1.704-2(j)(2)(i~~1.704-(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~5.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~5.1(d) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 5.1 (d)(v) and ~~Section 6.1(d)(vii~~(vi)). This Section ~~6.1(d)(i~~5.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Star Gas Finance Co

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i)~~, or any successor provision~~. For purposes of this Section 6.1(d), each Partner’s 's Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 6.1(d)(v) and ~~Section 6.1(d)(vii~~6.1(d)(vi)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Agreement (Tc Pipelines Lp)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital 52 Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 6.1(d)(vi) and Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: www.lw.com

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i)~~, or any successor provision~~. For purposes of this Section 6.1(d), each Partner’s 's Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to ~~Section~~ Sections 6.1(d)(vi) and ~~Section~~ 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Article Xiv Merger (Tc Pipelines Lp)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital 160 Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 6.1(d)(v) and ~~Section 6.1(d)(vii~~6.1(d)(vi)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Energy Transfer LP

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(d)(iv) and Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Marlin Midstream Partners, LP

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections ~~1.704-~~1.704- 2(f)(6), 1.704-~~2(g)(2~~2(g) (2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 6.1(d)(vi) and Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: www.lw.com

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), ~~1.704-2(g)(2~~1.7042(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 6.1(d)(v) and ~~Section 6.1(d)(vii~~6.1(d)(vi)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Martin Midstream Partners L.P.

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(b), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(b)(i) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(b)(v) and Section ~~6.1(d)(vii~~6.1(b)(vi)). This Section ~~6.1(d)(i~~6.1(b)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Penn Virginia Resource Partners L P

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), 28 or any successor provision. For purposes of this Section ~~6.1(d~~6.1(b), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(b) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 6.1(b)(vi) and ~~Section 6.1(d)(vii~~6.1(b)(vii)). This Section ~~6.1(d)(i~~6.1(b)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Partnership Agreement (CVR Refining, LP)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(c), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(c) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(c)(v) and Section ~~6.1(d)(vii~~6.1(c)(vi)). This Section ~~6.1(d)(i~~6.1(c)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Legacy Reserves Lp

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to ~~Section~~ Sections 6.1(d)(vi) ~~and Section~~ or 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Partnership Agreement (Stonemor Partners Lp)

Partnership Minimum Gain Chargeback. Notwithstanding any other ----------------------------------- provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any ~~Partnership~~ Company taxable period, each ~~Partner~~ Member shall be allocated items of ~~Partnership~~ Company income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each ~~Partner’s~~ Member's Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 6.1(d)(v) and ~~Section 6.1(d)(vii~~6.1(d)(vi)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: U S Timberlands Finance Corp

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to ~~Section~~ Sections 6.1(d)(vi) and ~~Section~~ 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently ~~therewith.~~therewith.‌

Appears in 1 contract

Samples: ir.energytransfer.com

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), ~~1.704-2(g)(2~~1.704‑2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(c), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(c) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(c)(vi) and Section ~~6.1(d)(vii~~6.1(c)(vii)). This Section ~~6.1(d)(i~~6.1(c)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Legacy Reserves Lp

Partnership Minimum Gain Chargeback. Notwithstanding any other ----------------------------------- provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any ~~Partnership~~ Company taxable period, each ~~Partner~~ Member shall be allocated items of ~~Partnership~~ Company income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections ~~1.704-~~1.704- 2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each ~~Partner’s~~ Member's Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 6.1(d)(v) and ~~Section 6.1(d)(vii~~6.1(d)(vi)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Operating Agreement (U S Timberlands Co Lp)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections ~~1.704-2(f)(6~~1.704‑2(f)(6), ~~1.704-2(g)(2~~1.704‑2(g)(2) and ~~1.704-2(j)(2)(i~~1.704‑2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 6.1(d)(vi) and Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section ~~1.704-2(f~~1.704‑2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Summit Midstream Partners, LP

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections ~~1.704-~~1.704- 2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(c), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(c) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(c)(v) and Section ~~6.1(d)(vii~~6.1(c)(vi)). This Section ~~6.1(d)(i~~6.1(c)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-~~2(f~~2 (f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Agreement

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any ~~Partnership~~ Company taxable period, each ~~Partner~~ Member shall be allocated items of ~~Partnership~~ Company income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury ~~Regulation~~ Regulations Sections ~~1.704-2(f)(6~~1.704 -2(f)(6), ~~1.704-2(g)(2~~1.704 -2(g)(2) and ~~1.704-2(j)(2)(i~~1.704 -2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d)~~6.1.3, each ~~Partner’s~~ Member's Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d)~~ 6.1.3 with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 6.1.3.5 and 6.1.3.6) ~~and Section 6.1(d)(vii))~~. This Section ~~6.1(d)(i)~~ 6.1.3.1 is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury ~~Regulation~~ Regulations Section ~~1.704-2(f~~1.704 -2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Operating Agreement (U S Timberlands Klamath Falls LLC)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(b), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(b) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(b)(vi) and Section ~~6.1(d)(vii~~6.1(b)(vii)). This Section ~~6.1(d)(i~~6.1(b)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.. ALON USA PARTNERS, LP FIRST AMENDED AND RESTATED AGREEMENT OF LIMITED PARTNERSHIP

Appears in 1 contract

Samples: Alon USA Partners, LP

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(c), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(c) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(c)(vi) and Section ~~6.1(d)(vii~~6.1(c)(vii)). This Section ~~6.1(d)(i~~6.1(c)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.. Enviva Partners, LP Second Amended and Restated Agreement of Limited Partnership 29

Appears in 1 contract

Samples: Enviva Partners, LP

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section ~~6.1~~5.3, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury ~~Regulation~~ Regulations Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~5.3(d)(i), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~5.3(d) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 5.3(d)(v) ~~and Section 6.1(d)(vii~~or 5.1(d)(vi)). This Section ~~6.1(d)(i~~5.3(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury ~~Regulation~~ Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Plum Creek Timber Co Inc

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), ~~1.704-~~1.704- 2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to ~~Section~~ Sections 6.1(d)(vi) and ~~Section~~ 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: media.corporate-ir.net

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any ~~Partnership~~ Company taxable period, each ~~Partner~~ Member shall be allocated items of ~~Partnership~~ Company income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury ~~Regulation~~ Regulations Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d)~~6.1.3, each ~~Partner’s~~ Member's Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d)~~ 6.1.3 with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi)~~ Sections 6.1.3.5 and ~~Section 6.1(d)(vii)~~6.1.3.6). This Section ~~6.1(d)(i)~~ 6.1.3.1 is intended to comply with the Partnership Minimum ~~Gain~~ G ain chargeback requirement in Treasury ~~Regulation~~ Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Operating Agreement (U S Timberlands Klamath Falls LLC)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section ~~6.1~~5.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~5.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~5.1(d) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 5.1(d)(vi) and ~~Section 6.1(d)(vii~~5.1(d)(vii)). This Section ~~6.1(d)(i~~5.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section ~~1.704-~~1.704 2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Ferrellgas Finance Corp

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(b), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(b) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1(b)(vi) and Section ~~6.1(d)(vii~~6.1(b)(vii)). This Section ~~6.1(d)(i~~6.1(b)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Agreement (Alon USA Partners, LP)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section ~~6.1~~5.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), ~~1.704-2(g)(2~~1.7042(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~5.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~5.1(d) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 5.1(d)(vi) and ~~Section 6.1(d)(vii~~5.1(d)(vii)). This Section ~~6.1(d)(i~~5.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Agreement (Ferrellgas L P)

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application Western Gas Partners, LP First Amended and Restated Agreement of Limited Partnership of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section 6.1(d)(vi) and Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Western Gas Partners LP

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable ~~period~~year, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~6.1(c), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~6.1(c) with respect to such taxable ~~period~~ year (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections 6.1(c)(v) and ~~Section 6.1(d)(vii~~6.1(c)(vi)). This Section ~~6.1(d)(i~~6.1(c)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Alliance Resource Partners Lp

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section ~~6.1~~‎6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section ~~6.1(d~~‎6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section ~~6.1(d~~‎6.1(d) with respect to such taxable period (other than an allocation pursuant to ~~Section 6.1(d)(vi~~Sections ‎6.1(d)(vi) and ~~Section 6.1(d)(vii~~‎6.1(d)(vii)). This Section ~~6.1(d)(i~~‎6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Genesis Energy Lp

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections ~~1.704-~~1.704- 2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1 (d)(vi) and Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Tesoro Logistics Lp

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.1, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable period, each Partner shall be allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in the manner and amounts provided in Treasury Regulation Sections 1.704-2(f)(6), 1.704-2(g)(2) and 1.704-2(j)(2)(i), or any successor provision. For purposes of this Section 6.1(d), each Partner’s Adjusted Capital Account balance shall be determined, and the allocation of income or gain required hereunder shall be effected, prior to the application of any other allocations pursuant to this Section 6.1(d) with respect to such taxable period (other than an allocation pursuant to Section ~~6.1(d)(vi~~6.1 (d)(vi) and Section 6.1(d)(vii)). This Section 6.1(d)(i) is intended to comply with the Partnership Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

Appears in 1 contract

Samples: Western Refining Logistics, LP

Common use of Partnership Minimum Gain Chargeback Clause in Contracts