Share of Minimum Gain definition

Share of Minimum Gain means for each Partner, the excess of (1) the sum of (a) the aggregate Non-Recourse Deductions allocated to such Partner (and such Partner's predecessors in interest) up to that time and (b) the aggregate distributions to such Partner (and such Partner's predecessors in interest) up to that time of proceeds of a non-recourse liability that are allocable to an increase in Partnership Minimum Gain over (2) the sum of (a) such Partner's (and such Partner's predecessors in interest) aggregate share of the net decrease in Partnership Minimum Gain up to that time and (b) such Partner's (and such Partner's predecessors in interest) aggregate share of the decreases up to that time in Partnership Minimum Gain resulting from revaluations of Partnership Property subject to one or more non-recourse liabilities of the Partnership, as more fully set forth in Treasury Regulation 1.704-2(g).
Share of Minimum Gain means, at a particular time with respect to a Shareholder, the amount of partnership minimum gain determined with respect to such Shareholder as of such time in accordance with Treasury Regulations Section 1.704-2(g)(1).
Share of Minimum Gain means, for each Partner, the sum of such Partner's share of Minimum Gain attributable to Nonrecourse Debt other than Partner Nonrecourse Debt (computed in accordance with Treasury Regulation ss.1.704-2(g)) and such Partner's share of Minimum Gain attributable to Partner Nonrecourse Debt (computed in accordance with Treasury Regulation ss.1.704-2(i)(5)).

Examples of Share of Minimum Gain 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).

  • 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).

  • In the event that during any fiscal year any Unit Holder unexpectedly receives such an adjustment, allocation or distribution, such Unit Holder will be allocated items of income and gain in an amount and manner sufficient to eliminate as quickly as possible any deficit balance in its capital account in excess of such Unit Holder's Pro Rata Share of Minimum Gain resulting from such unexpected adjustment, allocation or distribution.

  • The amount of such deficit balance which needs to be eliminated shall be reduced by the amount of such Venturer's Share of Partnership Minimum Gain and such Venturer'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).

  • No allocation shall be made to a Partner which would cause such Partner to have a deficit balance in its Adjusted Capital Account which exceeds the sum of such Partner's share of Partnership Minimum Gain and such Partner's Share of Minimum Gain Attributable to Partner Nonrecourse Debt.


More Definitions of Share of Minimum Gain

Share of Minimum Gain means, for each Partner, the excess, if any, of (i) the sum of the aggregate Non-Recourse Deductions allocated to such Partner (and such Partner’s predecessors in interest), cumulatively from the inception of the Partnership, and the aggregate distributions to such Partner (and such Partner’s predecessors in interest), cumulatively from the inception of the Partnership, of proceeds of a non-recourse liability that are allocable to an increase in Partnership Minimum Gain, over (ii) the sum of such Partner’s (and such Partner’s predecessors’) aggregate share (determined as described below) of any net decreases in Partnership Minimum Gain, cumulatively from the inception of the Partnership. For purposes of this Section 7.4: (a) a deduction shall constitute a “Non-Recourse Deduction” if, and to the extent that, at the time such item was incurred it increased the amount of the Partnership’s Minimum Gain; (b) a Partner’s share of the net decrease in Partnership Minimum Gain during a taxable year shall be an amount that bears the same relation to the net decrease in Minimum Gain during such year as such Partner’s Share of Minimum Gain at the end of the prior taxable year (or if later at the time immediately following the last time that the capital accounts of the Partners are increased pursuant to Treasury Regulation Section 1.704-1(b)(2)(iv)(f) or (r) to reflect the revaluation of Partnership property subject to one or more non-recourse liabilities of the Partnership) bears to the amount of Minimum Gain at the end of such prior taxable year (or such later date); (c) a Partner’s share of any decrease in Partnership Minimum Gain resulting from a revaluation of Partnership property equals the amount of the increase in such Partner’s Capital Account attributable to such revaluation to the extent of the reduction in Minimum Gain caused by such revaluation; (d) in determining the net increase or decrease in Partnership Minimum Gain during any Partnership taxable year in which the Capital Accounts of the Partners are increased pursuant to a revaluation of Partnership property subject to one or more non-recourse liabilities of the Partnership, any decrease in Partnership Minimum Gain attributable to each such revaluation shall be added back to the net decrease or increase otherwise determined; and (e) a distribution to a Partner by the Partnership that is allocable to the proceeds of any non-recourse liability of the Partnership is allocable to an increase in the Partne...
Share of Minimum Gain means for each Partner, the excess of (1) the sum of (a) the aggregate Non-Recourse Deductions allocated to such Partner (and such Partner's predecessors in interest) up to that time and (b) the aggregate distributions to such Partner (and such Partner's predecessors in interest) up to that time of proceeds of a non-recourse liability that are allocable to an increase in Partnership Minimum Gain over (2) the sum of (a) such Partner's (and such Partner's predecessors in interest) aggregate share of the net decrease in Partnership Minimum Gain up to that time and (b) such Partner's(and such Partner's predecessors in interest) aggregate share of the decreases up to that time in Partnership Minimum Gain resulting from revaluations of Partnership Property subject to one or more non-recourse liabilities of the Partnership,as more fully set forth in Treasury Regulation 1.704-2(g). "State" means the State of Connecticut. "State Designation" means, with respect to the Apartment Complex, the final allocation by the Agency of Low-Income Housing Tax Credits,as evidenced by the receipt by the Partnership of IRS Form 8609 executed by the Agency as to all buildings in the Apartment Complex. In the event State Designation is anticipated to occur more that sixty (60) days after the Agency's Cost Certification, then, for purposes of Section 5.01(c) hereof,State Designation shall mean evidence of the Agency's receipt of Cost Certification. "Subordinated Loan" means any loan made by the General Partner to the Partnership pursuant to Section 8.17. "Substantial Completion" means the date upon which the Partnership has received (a) both a certificate of substantial completion from the applicable inspecting architect certifying that the rehabilitation has been completed in accordance with the Plans and Specifications and (b), if applicable, certificates of substantial completion or certificates of occupancy from the applicable governmental jurisdiction(s) or authority(ies) for one hundred percent (100%) of the apartment units in the Apartment Complex; provided, however, that Substantial Completion shall not be deemed to have occurred if on such date any liens or other encumbrances as to title to the Land and the Apartment Complex exist (unless the General Partner shall have provided lien bonds ox xxxxx xxxxxxnce coverage satisfactory in amount and coverage to BCTC 94, Inc.), other than those securing the Mortgage Loan and/or those Consented to by the Investment Partnership. "Subs...
Share of Minimum Gain means, for each Member, the excess of (i) the sum of (a) the aggregate Nonrecourse Deductions allocated to such Member (and such Member's predecessors in interest) up to that time and (b) the aggregate distributions to such Member (and such Member's predecessors in interest) up to that time of proceeds of a non-recourse liability that are allocable to an increase in Minimum Gain over (ii) the sum of (a) such Member's (and such Member's predecessors in interest) aggregate share of the net decrease in Minimum Gain up to that time and (b) such Member's (and such Member's predecessors' in interest) aggregate share of the decreases up to that time in Minimum Gain resulting from revaluations of Company property subject to one or more non-recourse liabilities of the Company.
Share of Minimum Gain means, for each Member, the excess of (i) the sum of (a) the aggregate Nonrecourse Deductions allocated to such Member (and such Member’s predecessors in interest) up to that time and (b) the aggregate distributions to such Member (and such Member’spredecessors in interest) up to that time of proceeds of a non-recourse liability that are allocable to an increase in Minimum Gain over (ii) the sum of (a) such Member’s (and such Member’s predecessors in interest) aggregate share of the net decrease in Minimum Gain up to that time and(b) such Member’s (and such Member’s predecessors’ in interest) aggregate share of the decreases up to that time in Minimum Gain resulting from revaluations of Company property subject to one or more non-recourse liabilities of the Company.
Share of Minimum Gain means for each Partner, the excess of (1) the sum of (a) the aggregate Non-Recourse Deductions allocated to such Partner (and such Partner's predecessors in interest) up to that time and (b) the aggregate distributions to such Partner (and such Partner's predecessors in interest) up to that time of proceeds of a non-recourse liability that are allocable to an increase in Partnership Minimum Gain over (2) the sum of (a) such Partner's (and such Partner's predecessors' in interest) aggregate share of the net decrease in Partnership Minimum Gain up to that time and (b) such Partner's (and such Partner's predecessors' in interest) aggregate share of the decreases up to that time in Partnership Minimum Gain resulting from revaluations of Partnership Property subject to one or more non- recourse liabilities of the Partnership, as more fully set forth in Treasury Regulation 1.704-2(g). Site has the meaning given to it in the Federal Comprehensive Environmental Response, Compensation and Liability Act of 1980, 42 U.S.C. Sec. 9601 et seq., as amended, and shall also include any meaning given to it in any similar state or local statutes, ordinances, regulations or by- laws. Special Limited Partner means BCTC 94, Inc., a Delaware corporation, and any person who becomes a Special Limited Partner as provided herein, in its capacity as a special limited partner of the Partnership.
Share of Minimum Gain means for each Partner, the excess of (i) the --------------------- sum of (a) the aggregate non-recourse deductions (as defined below) allocated to such Partner (and such Partner's predecessors in interest) up to that time and (b) the aggregate Distributions to such Partner (and such Partner's predecessors in interest) up to that time of proceeds of a non-recourse liability that are allocable to an increase in Minimum Gain over (2) the sum of (a) such Partner's (and such Partner's predecessors' in interest) aggregate share of the net decrease in Minimum Gain up to that time and (b) such Partner's (and such Partner's predecessors' in interest) aggregate share of the decreases up to that time in Minimum Gain resulting from revaluations of
Share of Minimum Gain means for each Member, the excess of (1) the sum of (a) the aggregate Non-Recourse Deductions allocated to such Member (and such Member's predecessors in interest) up to that time and (b) the aggregate distributions to such Member (and such Member's predecessors in interest) up to that time of proceeds of a non-recourse liability that are allocable to an increase in Company Minimum Gain over (2) the sum of (a) such Member's (and such Member's predecessors' in interest) aggregate share of the net decrease in Company Minimum Gain up to that time and (b) such Member's (and such Member's predecessors' in interest) aggregate share of the decreases up to that time in Company Minimum Gain resulting from re-valuations of Company Property subject to one or more non-recourse liabilities of the Company, as more fully set forth in Treasury Regulation 1.704- 2(g).