Common use of Partnership Minimum Gain Chargeback Clause in Contracts

Partnership Minimum Gain Chargeback. If there is a net decrease in “partnership minimum gain” during any year, determined in accordance with the tiered partnership rules of Regulation §1.704-2(k), each Partner shall be allocated items of income and gain for such year equal to such Partner’s share of the net decrease in partnership minimum gain within the meaning of Regulation §1.704-2(g)(2), except to the extent not required by Regulation §1.704-2(f). To the extent that this subsection (a) is inconsistent with Regulation §1.704-2(f) or §1.704-2(k) or incomplete with respect to such regulations, the minimum gain chargeback provided for herein shall be applied and interpreted in accordance with such regulations.

Appears in 4 contracts

Samples: Limited Partnership Agreement (Equistar Chemicals Lp), Limited Partnership Agreement (Millennium Chemicals Inc), Limited Partnership Agreement (Millennium Chemicals Inc)

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Partnership Minimum Gain Chargeback. If there is a net decrease in "partnership minimum gain" during any year, determined in accordance with the tiered partnership rules of Regulation §1.704ss.1.704-2(k), each Partner shall be allocated items of income and gain for such year equal to such Partner’s 's share of the net decrease in partnership minimum gain within the meaning of Regulation §1.704ss.1.704-2(g)(2), except to the extent not required by Regulation §1.704ss.1.704-2(f). To the extent that this subsection (a) is inconsistent with Regulation §1.704ss.1.704-2(f) or §1.704ss.1.704-2(k) or incomplete with respect to such regulations, the minimum gain chargeback provided for herein shall be applied and interpreted in accordance with such regulations.

Appears in 3 contracts

Samples: Limited Partnership Agreement (Millennium Chemicals Inc), Limited Partnership Agreement (Lyondell Chemical Co), Limited Partnership Agreement (Equistar Chemicals Lp)

Partnership Minimum Gain Chargeback. If there is a net decrease in "partnership minimum gain" during any year, determined in accordance with the tiered partnership rules of Regulation §1.704(S)1.704-2(k), each Partner shall be allocated items of income and gain for such year equal to such Partner’s 's share of the net decrease in partnership minimum gain within the meaning of Regulation §1.704(S)1.704-2(g)(2), except to the extent not required by Regulation §1.704(S)1.704-2(f). To the extent that this subsection (a) is inconsistent with Regulation §1.704(S)1.704-2(f) or §1.704(S)1.704-2(k) or incomplete with respect to such regulations, the minimum gain chargeback provided for herein shall be applied and interpreted in accordance with such regulations.

Appears in 2 contracts

Samples: Limited Partnership Agreement (Lyondell Petrochemical Co), Limited Partnership Agreement (Lyondell Petrochemical Co)

Partnership Minimum Gain Chargeback. If there is a net decrease in ----------------------------------- "partnership minimum gain" during any year, determined in accordance with the tiered partnership rules of Regulation §Section 1.704-2(k), each Partner shall be allocated items of income and gain for such year equal to such Partner’s 's share of the net decrease in partnership minimum gain within the meaning of Regulation §Section 1.704-2(g)(2), except to the extent not required by Regulation §Section 1.704-2(f). To the extent that this subsection (a) is inconsistent with -------------- Regulation §Section 1.704-2(f) or §Section 1.704-2(k) or incomplete with respect to such regulations, the minimum gain chargeback provided for herein shall be applied and interpreted in accordance with such regulations.

Appears in 2 contracts

Samples: Limited Partnership Agreement (Equistar Chemicals Lp), Limited Partnership Agreement (Lyondell Chemical Co)

Partnership Minimum Gain Chargeback. If there is a net decrease in "partnership minimum gain" during any year, determined in accordance with the tiered partnership rules of Regulation §Section 1.704-2(k), each Partner shall be allocated items of income and gain for such year equal to such Partner’s 's share of the net decrease in partnership minimum gain within the meaning of Regulation §Sections 1.704-2(g)(2), except to the extent not required by Regulation §Section 1.704-2(f). To the extent that this subsection (aSection 4.4(a) is inconsistent with Regulation §Section 1.704-2(f) or §Section 1.704-2(k) or incomplete with respect to such regulations, the minimum gain chargeback provided for herein shall be applied and interpreted in accordance with such regulations.

Appears in 1 contract

Samples: Limited Partnership Agreement (Geon Co)

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Partnership Minimum Gain Chargeback. If there is a net decrease in ----------------------------------- "partnership minimum gain" during any year, determined in accordance with the tiered partnership rules of Regulation §1.704(S)1.704-2(k), each Partner shall be allocated items of income and gain for such year equal to such Partner’s 's share of the net decrease in partnership minimum gain within the meaning of Regulation §1.704(S)1.704-2(g)(2), except to the extent not required by Regulation §1.704(S)1.704-2(f). To the extent that this subsection (a) is inconsistent with ------------- Regulation §1.704(S)1.704-2(f) or §1.704(S)1.704-2(k) or incomplete with respect to such regulations, the minimum gain chargeback provided for herein shall be applied and interpreted in accordance with such regulations.

Appears in 1 contract

Samples: Limited Partnership Agreement (Equistar Funding Corp)

Partnership Minimum Gain Chargeback. If there is a net decrease in “partnership minimum gain” during any year, determined in accordance with the tiered partnership rules of Regulation §1.704-2(k), each Partner shall be be. allocated items of income and gain for such year equal to such Partner’s share of the net decrease in partnership minimum gain within the meaning of Regulation §1.704-2(g)(2), except to the extent not required by Regulation §1.704-2(f). To the extent that this subsection (a) is inconsistent with Regulation §1.704l.704-2(f) or §1.704-2(k) or incomplete with respect to such regulations, the minimum gain chargeback provided for herein shall be applied and interpreted in accordance with such regulations.

Appears in 1 contract

Samples: Limited Partnership Agreement (LyondellBasell F&F Holdco, LLC)

Partnership Minimum Gain Chargeback. If there is a net decrease in "partnership minimum gain" during any year, determined in accordance with the tiered partnership rules of Regulation §Section 1.704-2(k), each Partner shall be allocated items of income and gain for such year equal to such Partner’s 's share of the net decrease in partnership minimum gain within the meaning of Regulation §Section 1.704-2(g)(2), except to the extent not required by Regulation §Section 1.704-2(f). To the extent that this subsection (a) is inconsistent with Regulation §Section 1.704-2(f) or §Section 1.704-2(k) or incomplete with respect to such regulations, the minimum gain chargeback provided for herein shall be applied and interpreted in accordance with such regulations.

Appears in 1 contract

Samples: Limited Partnership Agreement (Occidental Petroleum Corp /De/)

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