Qualified Income Offset definition

Qualified Income Offset shall have the meaning set forth in Regulations Section 1.704-1(b)(2)(ii)(d).

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Qualified Income Offset provisions of Treasury Regulation Section 1.704-1(b)(2)(ii)

Qualified Income Offset shall have the meaning ascribed thereto in Section 1.704-2(b)(2)(ii)(d) of the Treasury Regulations, as it applies to the Company.

Examples of Qualified Income Offset in a sentence

As used herein, the term "Qualified Income Offset Amount" for a Partner means the excess, if any, of (x) the negative balance a Partner has in its Capital Account following the adjustment, allocation, or distribution described in the preceding sentence, over (y) the maximum amount that it is obligated (or is deemed to be obligated) to restore to the Partnership upon liquidation as determined in accordance with Regulations Sections 1.704-2(f), (g), and (i).
For purposes of this Section 10.1(c), a Partner's Capital Account shall be treated as reduced by Qualified Income Offset Items.
For the purposes of this Section 10.1(c), a Partner's Capital Account shall be treated as reduced by Qualified Income Offset Items.
Any losses which are not allocated to a Partner by virtue of the application of this Section 10.1(c) shall be allocated to the General Partners, excluding any General Partner which shall have been admitted pursuant to any of Section 4.5(b), Section 5.2(e), Section 6.2(b), Section 6.10 or Section 7.5. For purposes of this Section 10.1(c), a Partner's Capital Account shall be treated as reduced by Qualified Income Offset Items.
The allocations in the last sentence of the first paragraph of Section 14.3 (Losses and Other Items) and Sections 14.4 (Minimum Gain Chargeback), 14.5 (Member Nonrecourse Debt Minimum Gain), 14.6 (Qualified Income Offset), 14.7 (Gross Income Allocation), 14.8 (Nonrecourse Deductions), 14.9 (Member Nonrecourse Deductions) and 14.10 (Code Section 754 Adjustments) (the “Regulatory Allocations”) are intended to comply with certain requirements of the Regulations.

More Definitions of Qualified Income Offset

Qualified Income Offset provisions set forth in Exhibit B, Company Income or Loss for each Accounting Period shall be allocated one hundred percent (100%) to the Capital Accounts of the Members in proportion to their respective Company Percentages.

Qualified Income Offset. The allocations provided for in Article VII shall be subject to the following exceptions:

Qualified Income Offset pursuant to Regulation Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith.

Qualified Income Offset. See Section 3.5(a)(iii).

Qualified Income Offset. See Section 5.5.

Qualified Income Offset. (each as defined in the Regulations under Section 704 of the Code). No allocation of Net Loss (or items thereof) shall be made to any Member to the extent that such allocation would create or increase an Adjusted Capital Account Deficit with respect to such Member. In addition, all nonrecourse deductions (within the meaning of such Regulations) for any Fiscal Period shall be allocated to the Members in accordance with any permissible method under the applicable Regulations, and all “partner nonrecourse deductions” (within the meaning of such Regulations) for any Fiscal Period shall be allocated to the Member who bears the economic risk of loss with respect to the “partner nonrecourse debt” (within the meaning of such Regulations) to which such partner nonrecourse deductions are attributable in accordance with the Regulations under Section 704 of the Code.

Qualified Income Offset has the meaning set forth in Treasury Regulations Section 1.704-1(b)(2).