Common use of Partnership Minimum Gain Chargeback Clause in Contracts

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Article 6, if there is a net decrease in Minimum Gain during any tax year or other period for which allocations are made, the Members will be specially allocated items of Company income and gain for that period (and, if necessary, subsequent periods) in an amount equal to such Member’s share of the net decrease in Minimum Gain during such tax year or other period determined in accordance with Treasury Regulations Section 1.704-2(g)(2). Allocations pursuant to the preceding sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2)(i). This Section 6.2.A. (1) is intended to comply with the minimum gain chargeback requirements set forth in Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith, including the exceptions to the minimum gain chargeback requirement set forth in Treasury Regulations Sections 1.704-2(f)(2) and (3).

Partnership Minimum Gain Chargeback. Notwithstanding Except as otherwise provided in Treasury Regulation Section 1.704-2(f), notwithstanding any other provision of this Article 6, if there is a net decrease in Partnership Minimum Gain during any tax year or other period for which allocations are madeFiscal Year, the Members will each Partner shall be specially allocated items of Company Partnership income and gain for that period such Fiscal Year (and, if necessary, subsequent periodsFiscal Years) in an amount equal to each such MemberPartner’s share of the net decrease in Partnership Minimum Gain during Gain, as such tax year or other period share is determined in accordance with Treasury Regulations Regulation Section 1.704-2(g)(22(g). Allocations pursuant to the preceding sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items of Partnership income and gain to be so allocated shall be determined in accordance with Treasury Regulations Regulation Sections 1.704-2(f)(6) and 1.704-2(j)(2)(i2(j)(2). This Section 6.2.A. (1) is intended to comply with the minimum gain chargeback requirements set forth in requirement of Treasury Regulations Section Regulation 1.704-2(f) and shall be interpreted consistently therewith, including the exceptions to the minimum gain chargeback requirement requirements set forth in Treasury Regulations Regulation Sections 1.704-2(f)(2) and (3).

Partnership Minimum Gain Chargeback. Notwithstanding Except as otherwise provided in Treasury Regulation Section 1.704-2(f), notwithstanding any other provision of this Article 6VIII, if there is a net decrease in Minimum Gain partnership minimum gain during any tax year or other period for which allocations are madeFiscal Year, the Members will each Member shall be specially allocated items of Company income and gain for that period such Fiscal Year (and, if necessary, subsequent periodsFiscal Years) in an amount equal to such Member’s 's share of the net decrease in Minimum Gain during such tax year or other period partnership minimum gain, determined in accordance with Treasury Regulations Regulation Section 1.704-2(g)(22(g). Allocations pursuant to the preceding previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Regulation Sections 1.704-2(f)(6) and 1.704-2(j)(2)(i2(j)(2). This Section 6.2.A. (18.02(a) is intended to comply with the minimum gain chargeback requirements set forth requirement in Treasury Regulations Regulation Section 1.704-2(f) and shall be interpreted consistently therewith, including the exceptions to the minimum gain chargeback requirement set forth in Treasury Regulations Sections 1.704-2(f)(2) and (3).

Partnership Minimum Gain Chargeback. Notwithstanding Except as otherwise provided in Treasury Regulations Section 1.704-2(f), notwithstanding any other provision of this Article 6Agreement, if there is a net decrease in Partnership Minimum Gain during any tax year or other period for which allocations are madeAllocation Period, the Members will each Partner shall be specially allocated items of Company Partnership income and gain for that period such Allocation Period (and, if necessary, subsequent periodsAllocation Periods) in an amount equal to such MemberPartner’s share of the net decrease in Partnership Minimum Gain during such tax year or other period Gain, determined in accordance with Treasury Regulations Section 1.704-2(g)(21.704- 2(g). Allocations pursuant to the preceding previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2)(i2(j)(2). This Section 6.2.A. (16.3(a) is intended to comply with the minimum gain chargeback requirements set forth requirement in Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith, including the exceptions to the minimum gain chargeback requirement set forth in Treasury Regulations Sections 1.704-2(f)(2) and (3).

Partnership Minimum Gain Chargeback. Notwithstanding Except as otherwise provided in Treasury Regulation Section 1.704-2(f), notwithstanding any other provision of this Article 6VIII, if there is a net decrease in Minimum Gain partnership minimum gain during any tax year or other period for which allocations are madeFiscal Year, the Members will each Member shall be specially allocated items of Company income and gain for that period such Fiscal Year (and, if necessary, subsequent periodsFiscal Years) in an amount equal to such Member’s share of the net decrease in Minimum Gain during such tax year or other period partnership minimum gain, determined in accordance with Treasury Regulations Regulation Section 1.704-2(g)(22(g). Allocations pursuant to the preceding previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Regulation Sections 1.704-2(f)(62(0(6) and 1.704-2(j)(2)(i1.704¬2(j)(2). This Section 6.2.A. (18.02(a) is intended to comply with the minimum gain chargeback requirements set forth requirement in Treasury Regulations Regulation Section 1.704-2(f) and shall be interpreted consistently therewith, including the exceptions to the minimum gain chargeback requirement set forth in Treasury Regulations Sections 1.704-2(f)(2) and (3).

Partnership Minimum Gain Chargeback. Notwithstanding Except as otherwise provided in Section 1.704-2(f) of the Treasury Regulations, notwithstanding any other provision of this Article 6, if there is a net decrease in Partnership Minimum Gain during any tax year or other period for which allocations are madefiscal year, the Members will each Partners shall be specially allocated items of Company Partnership income and gain for that period such fiscal year (and, if necessary, subsequent periodsfiscal years) in an amount equal to such MemberPartner’s share of the net decrease in Partnership Minimum Gain during such tax year or other period Gain, determined in accordance with Treasury Regulations Section 1.704-2(g)(22(g). For purposes of this agreement, the term “Partnership Minimum Gain” shall have the same meaning ascribed to that tern in Section 1.704-2(d) of the Treasury Regulations. Allocations pursuant to the preceding sentence this Section 6.2.1 shall be made in proportion to the respective amounts required to be allocated to each Member Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2)(i)2(j)(2) of the Treasury Regulations. This Section 6.2.A. (1) 6.2.1 is intended to comply with the minimum gain chargeback requirements set forth requirement in Treasury Regulations Section 1.704-2(f) of the Treasury Regulations and shall be interpreted consistently therewith, including the exceptions to the minimum gain chargeback requirement set forth in Treasury Regulations Sections 1.704-2(f)(2) and (3).

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Article 6, if there is a net decrease in Minimum Gain during any tax year or other period for which allocations are made, the Members each Partner and Assignee will be specially allocated items of Company Partnership income and gain for that period (and, if necessary, subsequent periods) in an amount equal to such Member’s Person's share of the net decrease in Minimum Gain during such tax year or other period determined in accordance with Treasury Regulations Section 1.704-2(g)(2). Allocations pursuant to the preceding sentence shall be made in proportion to the respective amounts required to be allocated to each Member Partner and Assignee pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Sections 1.704-1.704- 2(f)(6) and 1.704-2(j)(2)(i). This Section 6.2.A.6.2.D (1) is intended to comply with the minimum gain chargeback requirements set forth in Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith, including the exceptions to the minimum gain chargeback requirement set forth in Treasury Regulations Sections 1.704-2(f)(2) and (3).

Partnership Minimum Gain Chargeback. Notwithstanding any other provision of this Article 6, if there is a net decrease in Minimum Gain during any tax year or other period for which allocations are made, the Members each Partner will be specially allocated items of Company Partnership income and gain for that period (and, if necessary, subsequent periods) in an amount equal to such Member’s Partner's share of the net decrease in Minimum Gain during such tax year or other period determined in accordance with Treasury Regulations Section 1.704-2(g)(2). Allocations pursuant to the preceding sentence shall be made in proportion to the respective amounts required to be allocated to each Member Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2)(i). This Section 6.2.A.6.2.D (1) is intended to comply with the minimum gain chargeback requirements set forth in Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith, including the exceptions to the minimum gain chargeback requirement set forth in Treasury Regulations Sections 1.704-2(f)(2) and (3).

Partnership Minimum Gain Chargeback. Notwithstanding Except as otherwise provided in Treasury Regulation Section 1.704-2(f), notwithstanding any other provision of this Article 65, if there is a net decrease in Partnership Minimum Gain during any tax year or other period for which allocations are madefiscal year, the Members will each Partner shall be specially allocated items of Company Partnership income and gain for that period such fiscal year (and, if necessary, subsequent periodsfiscal years) in an amount equal to such MemberPartner’s share of the net decrease in Partnership Minimum Gain during such tax year or other period Gain, determined in accordance with Treasury Regulations Regulation Section 1.704-2(g)(22(g). Allocations pursuant to the preceding previous sentence shall be made in proportion to the respective amounts required to be allocated to each Member Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Regulation Sections 1.704-2(f)(6) and 1.704-2(j)(2)(i2(j)(2). This Section 6.2.A. (15.05(a) is intended to comply with the partnership minimum gain chargeback requirements set forth requirement in Treasury Regulations Regulation Section 1.704-2(f) and shall be interpreted and applied consistently therewith, including the exceptions to the minimum gain chargeback requirement set forth in Treasury Regulations Sections 1.704-2(f)(2) and (3).