Fund Minimum Gain definition

Fund Minimum Gain has the meaning given the term “partnership minimum gain” in Sections 1.704-2(b)(2) and 1.704-2(d) of the Regulations.
Sample 1Sample 2Sample 3
Fund Minimum Gain means, with respect to the Fund, partnership minimum gain determined pursuant to Treasury Regulations Section 1.704-2(d).
Sample 1Sample 2Sample 3
Fund Minimum Gain means that amount, with respect to each Fund, determined in accordance with the principles of Treasury Regulation Section 1.704-2(d).
Sample 1

Examples of Fund Minimum Gain in a sentence

  • In the event there is a net decrease in the Fund Minimum Gain during any Fiscal Year, the minimum gain chargeback provisions described in Sections 1.704-2(f) and (g) of the Treasury Regulations will apply.

  • Except as otherwise provided in Section 1.704-2(f) of the Regulations, notwithstanding any other provision of this Article 4, if there is a net decrease in Fund Minimum Gain during any Accounting Period, each Member shall be specially allocated items of Fund income and gain for such Accounting Period (and, if necessary, subsequent Accounting Periods) in an amount equal to such Member’s share of the net decrease in Fund Minimum Gain, as determined in accordance with Section 1.704-2(g) of the Regulations.

  • If there is a net decrease in Fund Minimum Gain during any Fiscal Year, each Shareholder shall be allocated items of Fund income and gain for such Fiscal Year (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 Fund Minimum Gain during such Fiscal Year, determined in accordance with Treasury Regulations Section 1.704-2(g).

  • Except as otherwise provided in Regulations Section 1.704-2(f), notwithstanding any other provision of this ARTICLE 4, if there is a net decrease in Fund Minimum Gain during any year, each Member shall be specially allocated items of Fund income and gain for such year (and, if necessary, subsequent years) in an amount equal to such Member’s share of the net decrease in Fund Minimum Gain, determined in accordance with Regulations Section 1.704-2(g).

  • This Section 6.1(c)(i) is intended to comply with the Fund Minimum Gain chargeback requirement in Treasury Regulation section 1.704-2(f) and shall be interpreted consistently therewith.

  • To the extent required under Regulation Section 1.704-2(f), if there is a net decrease in Fund Minimum Gain during any fiscal year, each Member shall be allocated, before any other allocation of Fund items for such taxable year, items of Net Income for such year (and, if necessary, subsequent years), in proportion to, and to the extent of, an amount equal to the portion of such Member’s share of such net decrease in Minimum Gain as determined under Regulation Section 1.704-2(g).

  • This Article IV, Section 8(c)(i) is intended to comply with the Fund Minimum Gain chargeback requirement in Treasury Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.

  • Except as otherwise provided in §1.704-2(f) of the Treasury Regulations, notwithstanding any other provision of this Article III, if there is a net decrease in Fund Minimum Gain during any Fiscal Year, each Partner shall be specially allocated items of Fund income and gain for such Fiscal Year (and, if necessary, subsequent Fiscal Years) in an amount equal to such Partner’s share of the net decrease in Fund Minimum Gain, determined in accordance with Treasury Regulations §1.704-2(g).

  • Except as otherwise provided in Regulations Section 1.704-2(f), notwithstanding any other provision of this ‎ARTICLE 4, if there is a net decrease in Fund Minimum Gain during any year, each Member shall be specially allocated items of Fund income and gain for such year (and, if necessary, subsequent years) in an amount equal to such Member’s share of the net decrease in Fund Minimum Gain, determined in accordance with Regulations Section 1.704-2(g).

  • Notwithstanding any other provision of this Section 4, if there is a net decrease in Fund Minimum Gain during any Fund fiscal year, each Member shall be specially allocated items of Fund income and gain for such year (and, if necessary, subsequent years) in an amount equal to such Member’s share of the net decrease in Fund Minimum Gain, determined in accordance with Treasury Regulations Section 1.704-2(g)(2).


More Definitions of Fund Minimum Gain

Fund Minimum Gain has the same meaning as partnership minimum gain set forth in Treasury Regulations Section 1.704-2(d) and, as provided therein, shall generally be determined by computing, for each Nonrecourse Debt of the Fund, any gain the Fund would realize if it disposed of the property subject to that liability for no consideration other than full satisfaction of the liability, and then aggregating the separate amounts of gain so computed.
Sample 1Sample 2Sample 3
Fund Minimum Gain means “partnership minimum gain” as defined in Regulations Section 1.704-2(b)(2) and determined in accordance with Regulations Section 1.704-2(d).
Sample 1Sample 2Sample 3
Fund Minimum Gain shall have the same meaning as “partnership minimum gain” as set forth in Treasury Regulations Section 1.704-2(d).
Sample 1Sample 2
Fund Minimum Gain has the same meaning as partnership minimum gain set forth in Treasury Regulations Section 1.704-2(d) and, as provided therein, generally shall be determined by computing, for each Nonrecourse Debt of the Fund, any gain the Fund would realize if it disposed of the property subject to that liability for no consideration other than full satisfaction of the liability, and then aggregating the separate amounts of gain so computed.
Sample 1Sample 2
Fund Minimum Gain has the meaning set forth in Regulations Sections 1.704-2(b)(2) and 1.704-2(d).
Sample 1
Fund Minimum Gain means "partnership minimum gain” as set forth in Treasury Regulations Section I. 704-2(d).
Sample 1

Related to Fund Minimum Gain

  • Member Minimum Gain means an amount, with respect to each Member Nonrecourse Debt, equal to the Company Minimum Gain that would result if such Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Regulations Section 1.704-2(i)(3).

  • Company Minimum Gain has the meaning given the term “partnership minimum gain” in Sections 1.704-2(b)(2) and 1.704-2(d) of the Regulations.

  • Minimum Gain means “partnership minimum gain” determined pursuant to Treasury Regulation Section 1.704-2(d).

  • Member Nonrecourse Debt Minimum Gain means an amount, with respect to each Member Nonrecourse Debt, equal to the Company Minimum Gain that would result if such Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Section 1.704-2(i)(3) of the Regulations.

  • Nonrecourse Built-in Gain means with respect to any Contributed Properties or Adjusted Properties that are subject to a mortgage or pledge securing a Nonrecourse Liability, the amount of any taxable gain that would be allocated to the Partners pursuant to Section 6.2(b) if such properties were disposed of in a taxable transaction in full satisfaction of such liabilities and for no other consideration.

  • Adjusted Capital Account Deficit means, with respect to any Member, the deficit balance, if any, in such Member’s Capital Account as of the end of the relevant Fiscal Year, after giving effect to the following adjustments:

  • Member Nonrecourse Deduction means “partner nonrecourse deduction” as defined in Treasury Regulations Section 1.704-2(i), substituting the term “Member” for the term “partner” as the context requires.

  • Member Nonrecourse Debt has the meaning of “partner nonrecourse debt” set forth in Treasury Regulations Section 1.704-2(b)(4).

  • Nonrecourse Liability has the meaning set forth in Treasury Regulation Section 1.752-1(a)(2).

  • Nonrecourse Deductions has the meaning set forth in Section 1.704-2(b)(1) of the Regulations.

  • Adjusted Capital Account means the Capital Account maintained for each Partner as of the end of each Fiscal Year (i) increased by any amounts which such Partner is obligated to restore pursuant to any provision of this Agreement or is deemed to be obligated to restore pursuant to the penultimate sentences of Regulations Sections 1.704-2(g)(1) and 1.704-2(i)(5) and (ii) decreased by the items described in Regulations Sections 1.704-1(b)(2)(ii)(d)(4), 1.704-1(b)(2)(ii)(d)(5) and 1.704-1(b)(2)(ii)(d)(6). The foregoing definition of Adjusted Capital Account is intended to comply with the provisions of Regulations Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.

  • Partner Nonrecourse Deductions has the meaning set forth in Regulations Section 1.704-2(i)(2), and the amount of Partner Nonrecourse Deductions with respect to a Partner Nonrecourse Debt for a Partnership taxable year shall be determined in accordance with the rules of Regulations Section 1.704-2(i)(2).