Minimum Gain Attributable definition

Minimum Gain Attributable to a Member Nonrecourse Debt, with respect to any Member Nonrecourse Debt, shall mean the same as the partner’s share of partner nonrecourse debt minimum gain as provided in Treasury Regulation Section 1.704-2(i)(5).
View Source
Minimum Gain Attributable to a Member Nonrecourse Debt, with respect to any Member nonrecourse Debt, shall have the meaning ascribed to such term for purposes of Treasury Regulations Section 1.704-2(i)(5).
View Source

Examples of Minimum Gain Attributable in a sentence

  • The amount of such deficit balance which needs to be eliminated shall be reduced by the amount of such Partner's Share of Partnership Minimum Gain and such Partner's Share of Minimum Gain Attributable to Partner Nonrecourse Debt (computed, in each case, by reference to the amount of Partnership Minimum Gain and Minimum Gain Attributable to Partner Nonrecourse Debt after taking into account any changes thereto during such fiscal year).

  • If there is a net decrease in Minimum Gain Attributable to Partner Nonrecourse Debt during any fiscal year (other than as otherwise provided in Section 1.704-2(i)(4) of the Regulations), 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 the Partner’s share of the net decrease in the Minimum Gain Attributable to Partner Nonrecourse Debt.

  • The amount of such deficit balance which needs to be eliminated shall be reduced by the amount of such Partner's Share of Partnership Minimum Gain and such Partner's Share of Minimum Gain Attributable to Partner Nonrecourse Debt (computed, in each case, by reference to the amount of Partnership Minimum Gain and Minimum Gain Attributable to Partner Nonrecourse Debt after taking into account any changes thereto during such Fiscal Year).

  • For purposes of making allocations under this Section 5.1(b), a Partner's Capital Account balance shall be increased by the Partner's share of Partnership Minimum Gain and Minimum Gain Attributable to Partner Nonrecourse Debt as of the applicable time.

  • 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.

  • To the extent that the Partnership has insufficient income and gain in any Fiscal Year to make all of the allocations required under this Section 5.4(d), the insufficiency shall be attributed first to the decrease in Minimum Gain Attributable to Partner Nonrecourse Debt and second to the decrease in Minimum Gain.

  • For purposes of making allocations under this Section 5.1(a), a Partner's Capital Account balance shall be increased by the Partner's share of Partnership Minimum Gain and Minimum Gain Attributable to Partner Nonrecourse Debt as of the applicable time.

  • For purposes of this section, the amount of each Member's share of Company Minimum Gain and each Member's share of Minimum Gain Attributable to Member Nonrecourse Debt (each as hereinafter defined) shall be treated as a limited dollar deficit make-up obligation in such amounts and accordingly shall, for purposes of the preceding sentence, be added to the limited dollar amount (if any) of the deficit balance in such Member's Adjusted Book Capital Account that such Member is required to restore.

  • Chargeback of Minimum Gain Attributable to Member Nonrecourse Debt...........14 C.

  • Chargeback of Minimum Gain Attributable to Member Nonrecourse Debt C.

Related to Minimum Gain Attributable

  • Minimum Gain means “partnership minimum gain” determined pursuant to Treasury Regulation Section 1.704-2(d).

  • Member Minimum Gain means an amount, with respect to each Member Nonrecourse Debt, equal to the Company Minimum Gain that would result if such Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Regulations Section 1.704-2(i)(3).

  • Company Minimum Gain has the meaning given the term “partnership minimum gain” in Sections 1.704-2(b)(2) and 1.704-2(d) of the Regulations.

  • Member Nonrecourse Debt Minimum Gain means an amount, with respect to each Member Nonrecourse Debt, equal to the Company Minimum Gain that would result if such Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Regulations Section 1.704-2(i)(3).

  • Partner Nonrecourse Debt Minimum Gain has the meaning set forth in Treasury Regulation Section 1.704-2(i)(2).