Common use of Partner Nonrecourse Debt Minimum Gain Chargeback Clause in Contracts

Partner Nonrecourse Debt Minimum Gain Chargeback. Notwithstanding ------------------------------------------------ any other provision of this Section (other than Section 5.2(c)(1) which ----------------- shall be applied first), if there is a net decrease in Partner Nonrecourse Debt Minimum Gain during any taxable year or other period for which allocations are made, any Partner with a share of such Partner Nonrecourse Debt Minimum Gain attributable to such Partner Nonrecourse Debt (determined under Treasury Regulations Section 1.704-(2)(i)(5)) as of the beginning of the year shall be specially allocated items of Partnership income and gain for that period (and, if necessary, subsequent periods) in proportion to the portion of such Partner's share of the net decrease in the Partner Nonrecourse Debt Minimum Gain with respect to such Partner Nonrecourse Debt that is allocable to the disposition of Partnership property subject to such Partner Nonrecourse Debt. The items to be so allocated shall be determined in accordance with Regulations Section 1.704-2(g). This Section is intended to comply with the partner nonrecourse debt minimum gain chargeback requirements of the Treasury Regulations and the exceptions thereto and shall be interpreted consistently therewith.

Partner Nonrecourse Debt Minimum Gain Chargeback. Notwithstanding ------------------------------------------------ any other provision of this Section (other than Section 5.2(c)(14.2(c)(1) which ----------------- shall be applied first), if there is a net decrease in Partner Nonrecourse Debt Minimum Gain during any taxable year or other period for which allocations are made, any Partner with a share of such Partner Nonrecourse Debt Minimum Gain attributable to such Partner Nonrecourse Debt (determined under Treasury Regulations Section 1.704-(2)(i)(5)) as of the beginning of the year shall be specially allocated items of Partnership income and gain for that period (and, if necessary, subsequent periods) in proportion to the portion of such Partner's share of the net decrease in the Partner Nonrecourse Debt Minimum Gain with respect to such Partner Nonrecourse Debt that is allocable to the disposition Disposition of Partnership property subject to such Partner Nonrecourse Debt. The items to be so allocated shall be determined in accordance with Treasury Regulations Section 1.704-2(g). This Section is intended to comply with the partner nonrecourse debt minimum gain chargeback requirements of the Treasury Regulations and the exceptions thereto and shall be interpreted consistently therewith.

Partner Nonrecourse Debt Minimum Gain Chargeback. Notwithstanding ------------------------------------------------ Except as otherwise provided in Treas. Reg. § 1.704-2(i)(4), notwithstanding any other provision of this Section (other than Section 5.2(c)(1) which ----------------- shall be applied first)Agreement, if there is a net decrease in Partner Nonrecourse Debt Minimum Gain attributable to a Partner Nonrecourse Debt during any taxable year or other period for which allocations are madeFiscal Year, any each Partner with who has a share of such the Partner Nonrecourse Debt Minimum Gain attributable to such Partner Nonrecourse Debt (Debt, determined under Treasury Regulations Section 1.704-(2)(i)(5in accordance with Treas. Reg. § 1.704-2(i)(5)) as of the beginning of the year , shall be specially allocated items of Partnership income and gain for that period such Fiscal Year (and, if necessary, subsequent periodsFiscal Years) in proportion an amount equal to the portion of such Partner's ’s share of the net decrease in the Partner Nonrecourse Debt Minimum Gain with respect to such Partner Nonrecourse Debt that is allocable to the disposition of Partnership property subject attributable to such Partner Nonrecourse Debt, determined in accordance with Treas. Reg. §§ 1.704-2(i)(4). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Section Treas. Reg. §§ 1.704-2(g2(i)(4) and 1. 704-20)(2). This Section B.2.3(b) is intended to comply with the partner nonrecourse debt minimum gain chargeback requirements of the Treasury Regulations and the exceptions thereto requirement in Treas. Reg. § 1.704-2(i)(4) and shall be interpreted consistently therewith.

Partner Nonrecourse Debt Minimum Gain Chargeback. Notwithstanding ------------------------------------------------ any other provision provisions of this Section (other than Section 5.2(c)(14.01.3(a) which ----------------- shall be applied first), if there is a net decrease in Partner Nonrecourse Debt Minimum Gain during any taxable year or other period for which allocations are made, any Partner Member with a share of such Partner Nonrecourse Debt Minimum Gain attributable to such Partner Nonrecourse Debt any partner nonrecourse debt (determined under Treasury Regulations Section 1.704-(2)(i)(5)) as of the beginning of the year shall be specially allocated items of Partnership Company income and gain for that period (and, if necessary, subsequent periods) in proportion to the portion of such Partner's Member’s share of the net decrease in the Partner Nonrecourse Debt Minimum Gain with respect to such Partner Nonrecourse Debt partner nonrecourse debt that is allocable to the disposition of Partnership Company property subject to such Partner Nonrecourse Debtpartner nonrecourse debt. The items to be so allocated shall be determined in accordance with Treasury Regulations Section 1.704-2(g). This Section is intended to comply with the partner nonrecourse debt minimum gain chargeback requirements of the Treasury Regulations and the exceptions thereto and shall be interpreted consistently therewith.

Partner Nonrecourse Debt Minimum Gain Chargeback. Notwithstanding ------------------------------------------------ Except as otherwise provided in Treas. Reg. § 1.704-2(i)(4), notwithstanding any other provision of this Section (other than Section 5.2(c)(1) which ----------------- shall be applied first)Agreement, if there is a net decrease in Partner Nonrecourse Debt Minimum Gain attributable to a Partner Nonrecourse Debt during any taxable year or other period for which allocations are madeFiscal Year, any each Partner with who has a share of such the Partner Nonrecourse Debt Minimum Gain attributable to such Partner Nonrecourse Debt (Debt, determined under Treasury Regulations Section 1.704-(2)(i)(5in accordance with Treas. Reg. § 1.704-2(i)(5)) as of the beginning of the year , shall be specially allocated items of Partnership income and gain for that period such Fiscal Year (and, if necessary, subsequent periodsFiscal Years) in proportion an amount equal to the portion of such Partner's ’s share of the net decrease in the Partner Nonrecourse Debt Minimum Gain with respect to such Partner Nonrecourse Debt that is allocable to the disposition of Partnership property subject attributable to such Partner Nonrecourse Debt, determined in accordance with Treas. Reg. §§ 1.704-2(i)(4). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Section Treas. Reg. §§ 1.704-2(g2(i)(4) and 1.704-2(j)(2). This Section B.2.3(b) is intended to comply with the partner nonrecourse debt minimum gain chargeback requirements of the Treasury Regulations and the exceptions thereto requirement in Treas. Reg. § 1.704-2(i)(4) and shall be interpreted consistently therewith.

Partner Nonrecourse Debt Minimum Gain Chargeback. Notwithstanding ------------------------------------------------ Except as otherwise provided in Treasury Regulations Section 1.704-2(i)(4), notwithstanding any other provision of this Section (other than Section 5.2(c)(1) which ----------------- shall be applied first)Agreement, if there is a net decrease in Partner Nonrecourse Debt Minimum Gain attributable to a Partner Nonrecourse Debt during any taxable year or other period for which allocations are madeAllocation Period, any each Partner with who has a share of such the Partner Nonrecourse Debt Minimum Gain attributable to such Partner Nonrecourse Debt (Debt, determined under in accordance with Treasury Regulations Section 1.704-(2)(i)(51.704-2(i)(5)) as of the beginning of the year , shall be specially allocated items of Partnership income and gain for that period such Allocation Period (and, if necessary, subsequent periodsAllocation Periods) in proportion an amount equal to the portion of such Partner's ’s share of the net decrease in the Partner Nonrecourse Debt Minimum Gain with respect to such Partner Nonrecourse Debt that is allocable to the disposition of Partnership property subject attributable to such Partner Nonrecourse Debt, determined in accordance with Treasury Regulations Section 1.704-2(i)(4). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulations Section 1.704-2(g2(i)(4) and 1.704-2(j)(2). This Section 6.3(b) is intended to comply with the partner nonrecourse debt minimum gain chargeback requirements of the requirement in Treasury Regulations and the exceptions thereto Section 1.704-2(i)(4) and shall be interpreted consistently therewith.

Partner Nonrecourse Debt Minimum Gain Chargeback. Partner Nonrecourse Debt Minimum Gain Chargeback. Notwithstanding ------------------------------------------------ any other provision of this Section 4 (other than Section 5.2(c)(14.(b)(1) which ----------------- shall be applied first), if there is a net decrease in Partner Nonrecourse Debt Minimum Gain with respect to a Partner Nonrecourse Debt during any taxable year or other period for which allocations are made, any Partner Member with a share of such Partner Nonrecourse Debt Minimum Gain attributable to such Partner Nonrecourse Debt (determined under Treasury Regulations Section 1.704-(2)(i)(51.704-2(i)(5)) as of the beginning of the year shall will be specially allocated items of Partnership Company income and gain for that period (and, if necessary, subsequent periods) in proportion an amount equal to the portion of such PartnerMember's share of the net decrease in the Partner Nonrecourse Debt Minimum Gain during such year determined in accordance with respect to such Partner Nonrecourse Debt that is allocable to the disposition of Partnership property subject to such Partner Nonrecourse DebtRegulations Section 1.704-2(g)(2). The items to be so allocated shall will be determined in accordance with Regulations Section 1.704-2(g). This Section 4.(b)(2) is intended to comply with the partner nonrecourse debt minimum gain Partner Nonrecourse Debt Minimum Gain chargeback requirements of the Treasury Regulations and the exceptions thereto and shall Regulations, will be interpreted consistently therewithwith the Regulations and will be subject to all exceptions provided therein.