PARTNER NONRECOURSE DEBT MINIMUM. GAIN” has the meaning set forth in Regulations Section 1.704-2(i). A Partner’s share of Partner Nonrecourse Debt Minimum Gain shall be determined in accordance with Regulations Section 1.704-2(i)(5).
PARTNER NONRECOURSE DEBT MINIMUM. Gain" has the meaning set forth in Regulations Section 1.704-2(i).
PARTNER NONRECOURSE DEBT MINIMUM. Gain" is defined in Section 3.5.6 hereof.
More Definitions of PARTNER NONRECOURSE DEBT MINIMUM
PARTNER NONRECOURSE DEBT MINIMUM. GAIN" has the meaning set forth in Regulations Section 1.704-2(i).
PARTNER NONRECOURSE DEBT MINIMUM. Gain” shall be as defined in Treasury Regulations sections 1.704-2(i)(2) and 1.704-2(i)(3).
PARTNER NONRECOURSE DEBT MINIMUM. Gain" means an amount, with respect to each Partner Nonrecourse Debt, equal to the Partnership Minimum Gain that would result if such Partner Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Section 1.704-2(i)(3) of the Regulations.
PARTNER NONRECOURSE DEBT MINIMUM. Gain” shall have the meaning ascribed to such term in Section 4.04(b).
PARTNER NONRECOURSE DEBT MINIMUM gain” (within the meaning of Treasury Regulations Section 1.704- 2(i)(3)). (h) This Section 7.17(h)(i) incorporates by reference, as if fully set forth herein, the “minimum gain chargeback” requirement contained in Treasury Regulations Section 1.704- 2(f), the “partner minimum gain chargeback” requirement contained in Treasury Regulations Section 1.704-2(i), and the “qualified income offset” requirement contained in Treasury Regulations Section 1.704-1(b)(2)(ii)(d). (ii) In the event that any Holder of Subordinated Notes has a deficit capital account at the end of any Issuer taxable year that is in excess of the amount such Holder is deemed to be obligated to restore pursuant to the penultimate sentences of Treasury Regulations Sections 1.704-2(g)(1) and 1.704-2(i)(5), such Holder will be allocated items of Issuer income and gain in the amount of such excess as quickly as possible. Notwithstanding the foregoing, an allocation pursuant to this Section 7.17(h)(ii) will be made only if and to the extent that such Holder would have a deficit capital account in excess of such amount after all other allocations provided for in this Section 7.17 have been tentatively made as if this Section 7.17 did not include this Section 7.17(h)(ii) or the “qualified income offset” requirement of Section 7.17(h)(i). (iii) Nonrecourse deductions (within the meaning of Treasury Regulations Section 1.704-2(b)(1)) will be specially allocated to the Holders of Subordinated Notes in the same manner as if they were not nonrecourse deductions.
PARTNER NONRECOURSE DEBT MINIMUM. Gain” shall be determined as set forth in Section 1.704-2 (i) (2) of the Regulations, and, as provided therein, shall generally be the amount, with respect to each Partner Nonrecourse Debt, equal to the Partnership Minimum Gain that would result if such Partner Nonrecourse Debt were treated as a Nonrecourse Debt.
PARTNER NONRECOURSE DEBT MINIMUM. GAIN" shall have the meaning set forth in Section 6.1(d)(ii).