Regulatory Allocation Provisions Sample Clauses

Regulatory Allocation Provisions. Notwithstanding the foregoing provisions of this Article VI:

Regulatory Allocation Provisions. 5.4.1. Notwithstanding any other provision of this Agreement, if there is a net decrease in Partnership Minimum Gain during a Partnership taxable year, each Partner shall be specially allocated items of Partnership income and gain for such year (and, if necessary, for subsequent years) equal to such Partner's share of the net decrease in Partnership Minimum Gain (which share of such net decrease shall be determined under Regulations Section 1.704-2(g)(2)). It is intended that this Section 5.4 shall constitute a "minimum gain chargeback" as provided by Regulations Section 1.704-2(f). Such section of the Regulations shall control in the event of a conflict between such section and this Section 5.4. 5.4.2. Notwithstanding any other provision of this Agreement other than Section 5.4.1, if there is a net decrease in minimum gain during a Partnership taxable year attributable to a Partner Nonrecourse Debt, any Partner with a share of minimum gain attributable to such debt at the beginning of such year (as determined under Regulations Section 1.704-2(i)(5)) shall be specially allocated items of Partnership income and gain for such year (and, if necessary, for subsequent years) equal to that Partner's share of the net decrease in such minimum gain (which share of such net decrease shall be determined under Regulations Sections 1.704-2(i)(4) and 1.704-2(g)(2)). It is intended that this Section 5.4.2 shall constitute a chargeback of partner nonrecourse debt minimum gain as provided by Regulations Section 1.704- 2(i)(4) and such section of the Regulations shall control in the event of a conflict between such section and this Section 5.4.2. ▇.▇.▇. ▇▇ Items of Deduction or items of Partnership deduction or loss shall be allocated to any Partner to the extent that such allocation would result in such Partner having an Adjusted Capital Account Deficit. If any Partner unexpectedly receives any adjustments, allocations or distributions described in Regulations Section 1.704-1(b)(2) (ii)(d)(4) through (6) which result in an Adjusted Capital Account Deficit, such Partner shall be allocated items of Partnership income and gain in an amount and manner sufficient to eliminate such Adjusted Capital Account Deficit as quickly as possible, provided that an allocation pursuant to this Section 5.4.3 shall be made only if and to the extent that such Partner would have an Adjusted Capital Account Deficit after all other allocations provided for in this Article V (other than Section 5....

Regulatory Allocation Provisions. Notwithstanding any other provision in this Article IV: