Common use of Minimum Gain Attributable to Partner Nonrecourse Debt Clause in Contracts

Minimum Gain Attributable to Partner Nonrecourse Debt. Except as otherwise provided in Regulation Section 1.704-2(i)(4), if there is a net decrease in Minimum Gain Attributable to Partner Nonrecourse Debt during any fiscal year, 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 that Partner’s share of the net decrease in the Minimum Gain Attributable to Partner Nonrecourse Debt. The items to be so allocated shall be determined in accordance with Regulation Section 1.704-2(i)(4) and

Minimum Gain Attributable to Partner Nonrecourse Debt. Except as otherwise provided in Regulation Section 1.704-2(i)(4), if If there is a net decrease in Minimum Gain Attributable to Partner Nonrecourse Debt Minimum Gain of the Partnership during any fiscal year, 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 that Partner’s its share of the such net decrease in the Minimum Gain Attributable to Partner Nonrecourse Debt. The items to be so allocated shall be Debt Minimum Gain, as determined in accordance with Regulation Section Sections 1.704-2(i)(4) andand (j)(2). This Section ‎7(b)(ii) is intended to comply with the minimum gain chargeback requirement with respect to partner nonrecourse debt contained in said sections of the Regulations and shall be interpreted consistently therewith.