Minimum Gain Attributable to Partner Nonrecourse Debt definition

Minimum Gain Attributable to Partner Nonrecourse Debt means “partner nonrecourse debt minimum gain” as determined in accordance with Regulation Section 1.704-2(i)(2).
Minimum Gain Attributable to Partner Nonrecourse Debt. That amount determined in accordance with the principles of Treasury Regulations Sections 1.704-2(i)(3), (4) and (5).
Minimum Gain Attributable to Partner Nonrecourse Debt means "partner nonrecourse debt minimum gain" as determined in accordance with Regulation Section 1.704-2(i)(3).

Examples of Minimum Gain Attributable to Partner Nonrecourse Debt in a sentence

  • The amount of such deficit balance which needs to be eliminated shall be reduced by the amount of such Partner's Share of Partnership Minimum Gain and such Partner's Share of Minimum Gain Attributable to Partner Nonrecourse Debt (computed, in each case, by reference to the amount of Partnership Minimum Gain and Minimum Gain Attributable to Partner Nonrecourse Debt after taking into account any changes thereto during such fiscal year).

  • Partner's Share of Minimum Gain Attributable to Partner Nonrecourse Debt...............................................

  • If there is a net decrease in Minimum Gain Attributable to Partner Nonrecourse Debt during any fiscal year (other than as otherwise provided in Section 1.704-2(i)(4) of the Regulations), each Partner shall be specially allocated items of Partnership income and gain for such year (and, if necessary, subsequent years) in an amount equal to the Partner’s share of the net decrease in the Minimum Gain Attributable to Partner Nonrecourse Debt.

  • XXXXXXXX "Employee" AMENDMENT TO EMPLOYMENT AGREEMENT THIS AMENDMENT TO EMPLOYMENT AGREEMENT is made and entered into effective as of the 1st day of January, 2001 by and between AXXXXXXX FOODS OF DISTINCTION, INC., a Colorado corporation ("Corporation"), and WXXXXXX X.

  • The amount of such deficit balance which needs to be eliminated shall be reduced by the amount of such Partner's Share of Partnership Minimum Gain and such Partner's Share of Minimum Gain Attributable to Partner Nonrecourse Debt (computed, in each case, by reference to the amount of Partnership Minimum Gain and Minimum Gain Attributable to Partner Nonrecourse Debt after taking into account any changes thereto during such Fiscal Year).


More Definitions of Minimum Gain Attributable to Partner Nonrecourse Debt

Minimum Gain Attributable to Partner Nonrecourse Debt means that amount determined in accordance with the principles of Treasury Regulation section 1.704-2(i)(3).
Minimum Gain Attributable to Partner Nonrecourse Debt shall have the meaning set forth in Section 1.704-1T(b)(4)(iv)(h) of the Regulations.
Minimum Gain Attributable to Partner Nonrecourse Debt shall have the meaning set forth in Treas. Reg. ss. 1.704-1T(b)(4)(iv)(h).
Minimum Gain Attributable to Partner Nonrecourse Debt means "partner nonrecourse debt minimum gain" as determined in accordance with Regulation Section 1.704-2(i)(2). "Net Cash Flow" shall mean, with respect to any fiscal period of the Partnership, the excess, if any, of "Receipts" over "Expenditures." For purposes hereof, the term "Receipts" means the sum of all cash receipts of the Partnership from all sources for such period (including Net Sale Proceeds and Net Financing Proceeds but excluding Capital Contributions) and any amounts held as reserves as of the last day of such period which the General Partner reasonably deems to be in excess of necessary reserves as determined below. The term "Expenditures" means the sum of (a) all cash expenses of the Partnership for such period, (b) the amount of all payments of principal of, premium, if any, and interest on account of any indebtedness of the Partnership including payments of principal of, premium, if any, and interest on account of General Partner Loans, or amounts due on such indebtedness during such period, and (c) such additions to cash reserves as of the last day of such period as the General Partner deems necessary or appropriate
Minimum Gain Attributable to Partner Nonrecourse Debt means "partner nonrecourse debt minimum gain" as determined in accordance with Regulation Section 1.704-2(i)(2). "Net Financing Proceeds" shall mean the cash proceeds received by the Partnership in connection with any borrowing or refinancing of borrowing by or on behalf of the Partnership or by or on behalf of any Property Partnership (whether or not secured), after deduction of all costs and expenses incurred by the Partnership or the Property Partnership in connection with such borrowing, and after deduction of that portion of such proceeds used to repay any other indebtedness of the Partnership or Property Partnerships, or any interest or premium thereon. "Net Income or Net Loss" shall mean, for each fiscal year or other applicable period, an amount equal to the Partnership's net income or loss for such year or period as determined for federal income tax purposes by the Accountants, determined in accordance with Section 703(a) of the Code (for this purpose, all items of income, gain, loss or deduction required to be stated separately pursuant to Section 703(a) of the Code shall be included in taxable income or loss), with the following adjustments: (a) by including as an item of gross income any tax-exempt income received by the Partnership; (b) by treating as a deductible expense any expenditure of the Partnership described in Section 705(a)(2)(B) of the Code (including amounts paid or incurred to organize the Partnership (unless an election is made pursuant to Code Section 709(b)) or to promote the sale of interests in the Partnership and by treating deductions for any losses incurred in connection with the sale or exchange of Partnership property disallowed pursuant to
Minimum Gain Attributable to Partner Nonrecourse Debt is defined in the Allocations Exhibit.
Minimum Gain Attributable to Partner Nonrecourse Debt means that