Minimum Gain Attributable to Member Nonrecourse Debt definition

Minimum Gain Attributable to Member Nonrecourse Debt means “partner nonrecourse debt minimum gain” as determined in accordance with Treasury Regulations Section 1.704-2(i)(2).
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Minimum Gain Attributable to Member Nonrecourse Debt. The amount of gain which would be recognized by the Company for federal income tax purposes if all Company property secured by Member Nonrecourse Debt were transferred to the creditor of such debt in satisfaction thereof (and for no other consideration) in a taxable transaction. The amount of such gain shall be determined and calculated in accordance with Treasury Regulation Section 1.704-2(f) (i) (4).
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Minimum Gain Attributable to Member Nonrecourse Debt means that amount determined in accordance with the principles of Regulations Sections 1.704-2(i)(3), (4) and (5).
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Examples of Minimum Gain Attributable to Member Nonrecourse Debt in a sentence

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

  • Chargeback of Minimum Gain Attributable to Member Nonrecourse Debt.

  • In any Fiscal Year in which there is a net decrease in Minimum Gain Attributable to Member Nonrecourse Debt, then income and gain in the amount of the net decrease will be allocated to each Member who was considered to have had a share of such minimum gain at the beginning of the Fiscal Year in the ratio required by Treasury Regulation Sections 1.704-2(i)(4) and 1.704-2(j)(2)(ii).

  • Chargeback of Minimum Gain Attributable to Member Nonrecourse Debt C.


More Definitions of Minimum Gain Attributable to Member Nonrecourse Debt

Minimum Gain Attributable to Member Nonrecourse Debt means the amount of minimum gain there is in connection with a Member Nonrecourse Debt, calculated in the manner described in Treasury Regulation Section 1.704-2(i)(3).
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Minimum Gain Attributable to Member Nonrecourse Debt means that amount determined in accordance with the principles of Treasury Regulations Section 1.704-2(i)(3), (4) and (5).
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Minimum Gain Attributable to Member Nonrecourse Debt means the amount determined pursuant to the provisions of Treasury Regulations Section 1.704-2(i)(3).
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Minimum Gain Attributable to Member Nonrecourse Debt means the Company Minimum Gain attributable to Member Nonrecourse Debt as determined under the rules of Treasury Regulations Section 1.704-2(i).
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Minimum Gain Attributable to Member Nonrecourse Debt means "partner nonrecourse debt minimum gain" as determined in accordance with Regulations Section 1.704-2(i)(3).
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Minimum Gain Attributable to Member Nonrecourse Debt that amount with respect to each Member Nonrecourse Debt that is equal to the Company Minimum Gain that would result if such Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with the principles of Treasury Regulation Section 1.704-2(i)(3).
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Minimum Gain Attributable to Member Nonrecourse Debt means the
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