Common use of SHAREHOLDER NONRECOURSE DEBT MINIMUM GAIN CHARGEBACK Clause in Contracts

SHAREHOLDER NONRECOURSE DEBT MINIMUM GAIN CHARGEBACK. If there is a net decrease in Shareholder Nonrecourse Debt Minimum Gain during any Fiscal Year, each Shareholder shall be allocated items of Fund income and gain for such Fiscal Year or other period (and, if necessary, for subsequent Fiscal Years) in proportion to, and to the extent of, an amount equal to such Shareholder's share of the net decrease in Shareholder Nonrecourse Debt Minimum Gain during such Fiscal Year, determined in a manner consistent with the provisions of Treasury Regulations Section 1.704-2(g)(2). The requirement set forth in the preceding sentence shall be subject to the exceptions and limitations referred to in Treasury Regulations Section 1.704-2(i)(4). This Section 6.5(d) is intended to comply with the minimum gain chargeback requirement contained in Treasury Regulations Section 1.704-2(i)(4), and shall be construed so as to meet the requirements of said Treasury Regulation.

SHAREHOLDER NONRECOURSE DEBT MINIMUM GAIN CHARGEBACK. If there is a net decrease in Shareholder Nonrecourse Debt Minimum Gain during any Fiscal Year, each Shareholder shall be allocated items of Fund income and gain for such Fiscal Year or other period (and, if necessary, for subsequent Fiscal Years) in proportion to, and to the extent of, an amount equal to such Shareholder's share of the net decrease in Shareholder Nonrecourse Debt Minimum Gain during such Fiscal Year, determined in a manner consistent with the provisions of Treasury Regulations Section 1.704-2(g)(2). The requirement set forth in the preceding sentence shall be subject to the exceptions and limitations referred to in Treasury Regulations Section 1.704-2(i)(4). This Section 6.5(d6.7(d) is intended to comply with the minimum gain chargeback requirement contained in Treasury Regulations Section 1.704-2(i)(4), and shall be construed so as to meet the requirements of said such Treasury Regulation.

SHAREHOLDER NONRECOURSE DEBT MINIMUM GAIN CHARGEBACK. If there is a net decrease in Shareholder Nonrecourse Debt Minimum Gain during any Fiscal Year, each Shareholder shall be allocated items of Fund income and gain for such Fiscal Year or other period (and, if necessary, for subsequent Fiscal Years) in proportion to, and to the extent of, an amount equal to such Shareholder's share of the net decrease in Shareholder Nonrecourse Debt Minimum Gain during such Fiscal Year, determined in a manner consistent with the provisions of Treasury Regulations Section 1.704-2(g)(2). The requirement set forth in the preceding sentence shall be subject to the exceptions and limitations referred to in Treasury Regulations Section 1.704-2(i)(4). This Section 6.5(d6.7(d) is intended to comply with the minimum gain chargeback requirement contained in Treasury Regulations Section 1.704-2(i)(4), and shall be construed so as to meet the requirements of said Treasury Regulation.