Common use of Partner Nonrecourse Debt Minimum Gain Clause in Contracts

Partner Nonrecourse Debt Minimum Gain. Notwithstanding anything contained in this Article to the contrary, if there is a net decrease in Partner Nonrecourse Debt Minimum Gain, except as provided in Section 1.704-2(i) of the Treasury Regulations, items of Partnership income and gain for such Fiscal Year (and subsequent years, if necessary) in the order provided in Section 1.704-2(j)(2)(ii) of the Treasury Regulations shall be allocated among all Partners whose share of Partner Nonrecourse Debt Minimum Gain decreased during that year in proportion to and to the extent of such Partner’s share of the net decrease in Partner Nonrecourse Debt Minimum Gain during such year. This Section 4.3(b) is intended to comply with the minimum gain chargeback requirement in Section 1.704-2 of the Treasury Regulations and shall be interpreted consistently therewith.

Partner Nonrecourse Debt Minimum Gain. Notwithstanding anything contained in this Article IV to the contrary, if there is a net decrease in Partner Nonrecourse Debt Minimum Gain, except as provided in Section 1.704-2(i2(i)(4) of the Treasury Regulations, items of Partnership income and gain for such Fiscal Year (and subsequent years, if necessary) shall be allocated, in the order provided in Section 1.704-2(j)(2)(ii) of the Treasury Regulations shall be allocated Regulations, among all Partners whose share of Partner Nonrecourse Debt Minimum Gain decreased during that year in proportion to and to the extent of such each Partner’s share of the net decrease in Partner Nonrecourse Debt Minimum Gain during such year. This Section 4.3(b4.2(b) is intended to comply with the minimum gain chargeback requirement in Section 1.704-2 2(i)(4) of the Treasury Regulations and shall be interpreted consistently therewith.

Partner Nonrecourse Debt Minimum Gain. Notwithstanding anything contained in this Article IV to the contrary, if there is a net decrease in Partner Nonrecourse Debt Minimum Gain, except as provided in Section 1.704-2(i) of the Treasury Regulations, items of Partnership income and gain for such Fiscal Year taxable year (and subsequent years, if necessary) in the order provided in Section 1.704-2(j)(2)(ii1.704- 2(j)(2) of the Treasury Regulations shall be allocated among all Partners whose share of Partner Nonrecourse Debt Minimum Gain decreased during that year in proportion to and to the extent of such Partner’s share of the net decrease in Partner Nonrecourse Debt Minimum Gain during such year. This Section 4.3(b4.02(b) is intended to comply with the minimum gain chargeback requirement in Section 1.704-2 of the Treasury Regulations and shall be interpreted consistently therewith.