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: Agreement (Millennium Chemicals Inc), Lease Agreement (Equistar Chemicals Lp), Lease Agreement (Millennium Chemicals Inc)
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: Millennium Chemicals Inc, Lyondell Chemical Co, 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 §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: Lease Agreement (Equistar Chemicals Lp), Lease 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 §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: Lyondell Petrochemical Co, 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 1 contract
Samples: Occidental Petroleum Corp /De/
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
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: 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 §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.
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