Common use of Minimum Gain Chargebacks Clause in Contracts

Minimum Gain Chargebacks. Notwithstanding any other provision of this Article V, if there is a net decrease in Partnership Minimum Gain during any Partnership fiscal year, each Partner who has a share of Partnership Minimum Gain determined in accordance with Treas. Reg. §1.704- 2(g)(1) shall be specially allocated items of Partnership income and gain for such year (and, if necessary, subsequent years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain as provided by Treas. Reg. §1.704-2(g)(2). The items to be so allocated shall be determined in accordance with Regulation Section 1.704-2(f) and 1.704-2(j)(2)(i). The terms of this Section 5.05(a) are intended to comply with the minimum gain charge back requirements in such Sections of the Regulations and shall be interpreted consistently therewith. Limited Partnership Agreement of Cowtown Gas Processing Partners L.P. Page 9 of 35

Appears in 1 contract

Sources: Limited Partnership Agreement (Inergy Storage, Inc.)

Minimum Gain Chargebacks. Notwithstanding any other provision of this Article V, if there is a net decrease in Partnership Minimum Gain during any Partnership fiscal year, each Partner who has a share of Partnership Minimum Gain determined in accordance with Treas. Reg. §1.704- 1.704-2(g)(1) shall be specially allocated items of Partnership income and gain for such year (and, if necessary, subsequent years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain as provided by Treas. Reg. §1.704-2(g)(2). The items to be so allocated shall be determined in accordance with Regulation Section 1.704-2(f) and 1.704-2(j)(2)(i). The terms of this Section 5.05(a) are intended to comply with the minimum gain charge back requirements in such Sections of the Regulations and shall be interpreted consistently therewith. Limited Partnership Agreement of Cowtown Gas Processing Pipeline Partners L.P. Page 9 of 35

Appears in 1 contract

Sources: Limited Partnership Agreement (Inergy Storage, Inc.)