Common use of Special Allocations of Profits and Losses Clause in Contracts

Special Allocations of Profits and Losses. (a) Minimum Gain Chargeback--Partnership Nonrecourse Liabilities. If there is a net decrease in Partnership Minimum Gain during any Partnership taxable year, certain items of income and gain shall be allocated (on a gross basis) to the Partners in the amounts and manner described in Section 1.704-2(f) and (j)(2)(i) and (iii) of the Regulations, subject to the exemptions set forth in Section 1.704-2(f)(2), (3), (4) and (5) of the Regulations. This Section 5.2(a) is intended to comply with the minimum gain chargeback requirement (set forth in Section 1.704-2(f) of the Regulations) relating to Partnership nonrecourse liabilities (as defined in Section 1.704-2(b)(3) of the Regulations) and shall be so interpreted.

Special Allocations of Profits and Losses. (a) Minimum Gain Chargeback--Partnership Nonrecourse Liabilities. If there is a net decrease in Partnership Minimum Gain during any Partnership taxable year, certain items of income and gain shall be allocated (on a gross basis) to the Partners in the amounts and manner described in Section section 1.704-2(f) and (j)(2)(i) and (iii) of the Regulations, subject to the exemptions set forth in Section section 1.704-2(f)(2), (3), (4) ), and (5) of the Regulations. This Section 5.2(a) is intended to comply with the minimum gain chargeback requirement (set forth in Section section 1.704-2(f) of the Regulations) relating to Partnership nonrecourse liabilities (as defined in Section section 1.704-2(b)(3) of the Regulations) and shall be so interpreted.