Common use of Qualified Income Offset Clause in Contracts

Qualified Income Offset. In the event any Partner unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulation Sections 1.704-1(b)(2)(ii)(d)(4), (5), or (6), items of Partnership income and gain shall be specially allocated to such Partner in an amount and manner sufficient to eliminate, to the extent required by the Treasury Regulations promulgated under Section 704(b) of the Code, the deficit balance, if any, in its Adjusted Capital Account created by such adjustments, allocations or distributions as quickly as possible unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(i) or (ii). This Section 6.1(d)(iii) is intended to qualify and be construed as a “qualified income offset” within the meaning of Treasury Regulation Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. In the event any Partner Member unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulation Regulations Sections 1.704-1(b)(2)(ii)(d)(4), (5), or (6), items of Partnership Company income and gain shall be specially allocated to such Partner Member in an amount and manner sufficient to eliminate, to the extent required by the Treasury Regulations promulgated under Section 704(b) of the Code, the deficit balance, if any, in its Adjusted Capital Account created by such adjustments, allocations or distributions as quickly as possible possible, unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(i5.1(b)(i) or (ii). This Section 6.1(d)(iii5.1(b)(iii) is intended to qualify and be construed as a “qualified income offset” within the meaning of Treasury Regulation Regulations Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. In the event any Partner Member unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulation Sections 1.704-1(b)(2)(ii)(d)(4), (5), or (6), items of Partnership Company income and gain shall be specially allocated to such Partner Member in an amount and manner sufficient to eliminate, to the extent required by the Treasury Regulations promulgated under Section 704(b) of the Code, the deficit balance, if any, in its Adjusted Capital Account created by such adjustments, allocations or distributions as quickly as possible unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(iSections 4.1(d)(i) or (ii). This Section 6.1(d)(iii4.1(d)(iii) is intended to qualify and be construed as a “qualified income offset” within the meaning of Treasury Regulation Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. In the event any Partner unexpectedly receives any adjustments, allocations or distributions described in U.S. Treasury Regulation Regulations Sections 1.704-1(b)(2)(ii)(d)(4), (5), or (6), items of Partnership income and gain shall be specially allocated to such Partner in an amount and manner sufficient to eliminate, to the extent required by the U.S. Treasury Regulations promulgated under Section 704(b) of the Code, the deficit balance, if any, in its Adjusted Capital Account created by such adjustments, allocations or distributions as quickly as possible unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(iSections 5.2(b)(i) or (ii). This Section 6.1(d)(iii5.2(b)(iii) is intended to qualify and be construed as a “qualified income offset” within the meaning of U.S. Treasury Regulation Regulations Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. In the event any Partner Member unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulation Regulations Sections 1.704-1(b)(2)(ii)(d)(4), (5), or (6), items of Partnership Company income and gain shall be specially allocated to such Partner Member in an amount and manner sufficient to eliminate, to the extent required by the Treasury Regulations promulgated under Section 704(b) of the Code, the deficit balance, if any, in its Adjusted Capital Account created by such adjustments, allocations or distributions as quickly as possible possible, unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(i5.1(b)(i) or (iiSection 5.1(b)(ii). This Section 6.1(d)(iii5.1(b)(iii) is intended to qualify and be construed as a “qualified income offset” within the meaning of Treasury Regulation Regulations Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. In the event any Partner unexpectedly receives any adjustments, allocations or distributions described in U.S. Treasury Regulation Regulations Sections 1.704-1(b)(2)(ii)(d)(4), (5), or (6), items of Partnership income and gain shall be specially allocated to such Partner in an amount and manner sufficient to eliminate, to the extent required by the U.S. Treasury Regulations promulgated under Section 704(b) of the Code, the deficit balance, if any, in its Adjusted Capital Account created by such adjustments, allocations or distributions as quickly as possible unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(iSections 5.1(b)(i) or (ii). This Section 6.1(d)(iii5.1(b)(iii) is intended to qualify and be construed as a “qualified income offset” within the meaning of U.S. Treasury Regulation Regulations Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. In the event any Partner unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulation Sections 1.704-1(b)(2)(ii)(d)(4), (5), or (6), items of Partnership income and gain shall be specially allocated to such Partner in an amount and manner sufficient to eliminate, to the extent required by the Treasury Regulations promulgated under Section 704(b) of the Code, the deficit balance, if any, in its Adjusted Capital Account created by such adjustments, allocations or distributions as quickly as possible unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(i6.1(e)(i) or (ii). This Section 6.1(d)(iii6.1(e)(iii) is intended to qualify and be construed as a “qualified income offset” within the meaning of Treasury Regulation Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. In Except as provided in Sections 9.2(c) and 9.2(d) above, in the event any Partner Member unexpectedly receives any adjustmentsan adjustment, allocations allocation or distributions distribution described in Treasury Regulation Sections 1.704-1(b)(2)(ii)(d)(4), (5), ) or (6), items of Partnership Company income and gain shall be specially allocated to such Partner Member in an amount and manner sufficient to eliminate, to the extent required by the such Treasury Regulations promulgated under Section 704(b) of the CodeRegulation, the deficit balance, if any, in its Adjusted Capital Account created by such adjustmentsadjustment, allocations allocation or distributions distribution as quickly as possible unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(iSections 9.2(c), 9.2(d) or (ii9.2(f). This Section 6.1(d)(iii9.2(e) is intended to qualify and be construed as constitute a “qualified income offset” within the meaning of offset described in Treasury Regulation Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. In the event any Partner Member unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulation Regulations Sections 1.704-1(b)(2)(ii)(d)(4), (5), or (6), items of Partnership Company income and gain shall be specially allocated to such Partner Member in an amount and manner sufficient to eliminate, to the extent required by the Treasury Regulations promulgated under Section 704(b) of the Code, the deficit balance, if any, in its Adjusted Capital Account created by such adjustments, allocations or distributions as quickly as possible possible, unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(i5.1(b)(i) or (iiSection 5.1(b)(ii). This Section 6.1(d)(iii5.1(b)(iii) is intended to qualify and be construed as a “qualified income offset” within the meaning of Treasury Regulation Regulations Section 1.704-1.704- 1(b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. In the event any Partner unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulation Sections 1.704-1(b)(2)(ii)(d)(4), (5), or (6), items of Partnership income and gain shall be specially allocated to such Partner in an amount and manner sufficient to eliminate, to the extent required by the Treasury Regulations promulgated under Section 704(b) of the Code, the deficit balance, if any, in its Adjusted Capital Account created by such adjustments, allocations or distributions as quickly as possible unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(i6.1(c)(i) or (ii). This Section 6.1(d)(iii6.1(c)(iii) is intended to qualify and be construed as a “qualified income offset” within the meaning of Treasury Regulation Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. In Except as provided in Sections 9.2(c) and 9.2(d) above, in the event any Partner Member unexpectedly receives any adjustmentsan adjustment, allocations allocation or distributions distribution described in Treasury Regulation Sections 1.704-1(b)(2)(ii)(d)(4), (5), ) or (6), items of Partnership Company income and gain shall be specially allocated to such Partner Member in an amount and manner sufficient to eliminate, to the extent required by the such Treasury Regulations promulgated under Section 704(b) of the CodeRegulation, the deficit balance, if any, in its Adjusted Capital Account created by such adjustmentsadjustment, allocations allocation or distributions distribution as quickly as possible unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(iSections 9.2(c) or (ii9.2(d). This Section 6.1(d)(iii9.2(e) is intended to qualify and be construed as constitute a “qualified income offset” within the meaning of offset described in Treasury Regulation Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. In the event any Partner unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulation Sections 1.704-1(b)(2)(ii)(d)(4), (5), or (6), items of Partnership income and gain shall be specially allocated to such Partner in an amount and manner sufficient to eliminate, to the extent required by the Treasury Regulations promulgated under Section 704(b) of the Code, the deficit balance, if any, in its Adjusted Capital Account created by such adjustments, allocations or distributions as quickly as possible unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(i) or (ii). This Section 6.1(d)(iii) is intended to qualify and be construed as a “"qualified income offset” " within the meaning of Treasury Regulation Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. In the event any Partner Member unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulation Regulations Sections 1.704-1(b)(2)(ii)(d)(4), (5), or (6), items of Partnership Company income and gain shall be specially allocated to such Partner Member in an amount and manner sufficient to eliminate, to the extent required by the Treasury Regulations promulgated under Section 704(b) of the Code, the deficit balance, if any, in its Adjusted Capital Account created by such adjustments, allocations or distributions as quickly as possible possible, unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(i5.1(e)(i) or (ii). This Section 6.1(d)(iii5.1(e)(iii) is intended to qualify and be construed as a “qualified income offset” within the meaning of Treasury Regulation Regulations Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. In the event any Partner Member unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulation Regulations Sections 1.704-1(b)(2)(ii)(d)(4l(b)(2)(ii)(d)(4), (5), or (6), items of Partnership Company income and gain shall be specially allocated to such Partner Member in an amount and manner sufficient to eliminate, to the extent required by the Treasury Regulations promulgated under Section 704(b) of the Code, the deficit balance, if any, in its Adjusted Capital Account created by such adjustments, allocations or distributions as quickly as possible possible, unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(i5.l(b)(i) or (iiSection 5.1(b)(ii). This Section 6.1(d)(iii5.1(b)(iii) is intended to qualify and be construed as a “qualified income offset” within the meaning of Treasury Regulation Regulations Section 1.704-1(b)(2)(ii)(d1 (b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. In the event any Partner Member unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulation Sections 1.704-1(b)(2)(ii)(d)(4), (5), or (6), items of Partnership Company income and gain shall be specially allocated to such Partner Member in an amount and manner sufficient to eliminate, to the extent required by the Treasury Regulations promulgated under Section 704(b) of the Code, the deficit balance, if any, in its Adjusted Capital Account created by such adjustments, allocations or distributions as quickly as possible unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(iSections 4.1(d)(i) or (ii). This Section 6.1(d)(iii4.1(d)(iii) is Table of Contents intended to qualify and be construed as a “qualified income offset” within the meaning of Treasury Regulation Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. In the event any Partner Member unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulation Sections 1.704-1(b)(2)(ii)(d)(4), (5), or (6), items of Partnership Company income and gain shall be specially allocated to such Partner Member in an amount and manner sufficient to eliminate, to the extent required by the Treasury Regulations promulgated under Section 704(b) of the Code, the deficit balance, if any, in its Adjusted Capital Account created by such adjustments, allocations or distributions as quickly as possible unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(iSections 4.1(c)(i) or (ii). This Section 6.1(d)(iii4.1(c)(iii) is intended to qualify and be construed as a “"qualified income offset” " within the meaning of Treasury Regulation Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. In Except as provided in Section 8.2(c) and Section 8.2(d) above, in the event any Partner Member unexpectedly receives any adjustmentsan adjustment, allocations allocation or distributions distribution described in Treasury Regulation Regulations Sections 1.704-1(b)(2)(ii)(d)(4), (5), ) or (6), items of Partnership Company income and gain shall be specially allocated to such Partner Member in an amount and manner sufficient to eliminate, to the extent required by the such Treasury Regulations promulgated under Section 704(b) of the CodeRegulation, the deficit balance, if any, in its Adjusted Capital Account created by such adjustmentsadjustment, allocations allocation or distributions distribution as quickly as possible unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(i8.2(c) or (iiSection 8.2(d). This Section 6.1(d)(iii8.2(e) is intended to qualify and be construed as constitute a “qualified income offset” within the meaning of offset described in Treasury Regulation Regulations Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. In the event any Partner unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulation Sections 1.704-1(b)(2)(ii)(d)(4), (5), or (6), items of Partnership income and gain shall be specially allocated to such Partner in an amount and manner sufficient to eliminate, to the extent required by the Treasury Regulations promulgated under Section 704(b) of the Code, the deficit balance, if any, in its Adjusted Capital Account created by such adjustments, allocations or distributions as quickly as possible unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(i) or (ii). This Section 6.1(d)(iii) is intended to qualify and be construed as a “qualified income offset” within the meaning of Treasury Regulation Section 1.704-1(b)(2)(ii)(dl(b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. In the event any Partner Member unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulation Sections 1.704-1(b)(2)(ii)(d)(4), (5), or (6), items of Partnership Company income and gain shall be specially allocated to such Partner Member in an amount and manner sufficient to eliminate, to the extent required by the Treasury Regulations promulgated under Section 704(b) of the Code, the deficit balance, if any, in its Adjusted Capital Account created by such adjustments, allocations or distributions as quickly as possible unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(iSections 4.1(c)(i) or (ii). This Section 6.1(d)(iii4.1(c)(iii) is intended to qualify and be construed as a “qualified income offset” within the meaning of Treasury Regulation Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. In the event any Partner unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulation Sections 1.704-1(b)(2)(ii)(d)(4), (5), or (6), items of Partnership income and gain shall be specially allocated to such Partner in an amount and manner sufficient to eliminate, to the extent required by the Treasury Regulations promulgated under Section 704(b) of the Code, the deficit balance, if any, in its Adjusted Capital Account created by such adjustments, allocations or distributions as quickly as possible unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(i6.l(c)(i) or (ii). This Section 6.1(d)(iii6.1(c)(iii) is intended to qualify and be construed as a “qualified income offset” within the meaning of Treasury Regulation Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. In the event any Partner unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulation Sections 1.704-1(b)(2)(ii)(d)(4), (5), or (6), items of Partnership income and gain shall be specially allocated to such Partner in an amount and manner sufficient to eliminate, to the extent required by the Treasury Regulations promulgated under Section 704(b) of the Code, the deficit balance, if any, in its Adjusted Capital Account created by such adjustments, allocations or distributions as quickly as possible unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(i6.1(c)(i) or (ii). This Section 6.1(d)(iii6.1(c)(iii) is intended to qualify and be construed as a “"qualified income offset” " within the meaning of Treasury Regulation Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. In the event any Partner Member unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulation Sections 1.704-1(b)(2)(ii)(d)(4), (5), or Table of Contents (6), items of Partnership Company income and gain shall be specially allocated to such Partner Member in an amount and manner sufficient to eliminate, to the extent required by the Treasury Regulations promulgated under Section 704(b) of the Code, the deficit balance, if any, in its Adjusted Capital Account created by such adjustments, allocations or distributions as quickly as possible unless such deficit balance is otherwise eliminated pursuant to Section 6.1(d)(iSections 4.1(c)(i) or (ii). This Section 6.1(d)(iii4.1(c)(iii) is intended to qualify and be construed as a “qualified income offset” within the meaning of Treasury Regulation Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.