Nonrecourse Minimum Gain definition

Nonrecourse Minimum Gain of the Partnership shall mean the amount of “minimum gain” of the Partnership that is attributable to Nonrecourse Liabilities (as determined strictly in accordance with sections 1.704-2(d) and 1.704-2(k) of the Regulations).
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Nonrecourse Minimum Gain means the amount determined as follows: (a) first, compute, with respect to each Nonrecourse Liability, the amount of Book Gain or Gross Income that would be realized by Palace if Palace disposed of (in a taxable transaction) Palace property subject to such debt in full satisfaction of such debt (and for no other consideration); and (b) then, add together the amounts so computed for all Nonrecourse Liabilities. The resulting sum is the "Nonrecourse Minimum Gain". Where any Palace property is subject to multiple secured liabilities of unequal priority, the property's Book Basis shall be allocated among the liabilities in order of priority from most senior first to least senior last. Where two or more secured liabilities are of equal priority, Book Basis shall be allocated among the liabilities in accordance with the outstanding balances of such liabilities. For purpose of determining the net increase or decrease in Nonrecourse Minimum Gain during any Fiscal Year in which the Members' Capital Accounts are increased pursuant to section 1.704-1(b)(2)(iv)(f) or (r) of the Regulations to reflect a revaluation of Palace property subject to one or more Nonrecourse Liabilities, any decrease in Nonrecourse Minimum Gain attributable to this revaluation shall be added back to the net decrease or increase otherwise determined. A Member's share of such "Nonrecourse Minimum Gain" shall be calculated in accordance with the provisions of section 1.704-2(g) of the Regulations.
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Nonrecourse Minimum Gain of the Company shall mean the amount of "minimum gain" of the Company that is attributable to Nonrecourse Liabilities (as determined strictly in accordance with Section 1.704-2(d) of the Regulations). A Member's share of such "Nonrecourse Minimum Gain" shall be calculated in accordance with the provisions of Section 1.704-2(g) of the Regulations.
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Examples of Nonrecourse Minimum Gain in a sentence

  • In the event there is a net decrease in Partner Nonrecourse Minimum Gain during any Fiscal Year, the “partner minimum gain chargeback” described in Regulations Section 1.704-2(i)(4) shall apply.

  • Section 1.704-2(b)(2)), and Partner Nonrecourse Minimum Gain (within the meaning of Treas.

  • In exercising its discretion under this Section, the Board shall take into account future Regulatory Allocations under Sections 5.3.1 and 5.3.2 that, although not yet made, are likely to offset other Regulatory Allocations previously made under Sections 5.3.5 and 5.3.6 and/or distributions of the Company which are included in a Member’s share of the Company’s Minimum Gain or Member Nonrecourse Minimum Gain.

  • The amount that would otherwise be subject to the Member Nonrecourse Minimum Gain chargeback is added to the Member's share of Company Minimum Gain under Treasury Regulations Section 1.704-2(g)(3).

  • Section 1.704-2(b)(2)) or Member Nonrecourse Minimum Gain (within the meaning of Treas.

  • Section 1.704-2(b)(2)) or Partner Nonrecourse Minimum Gain (within the meaning of Treas.

  • For purposes of determining a Partner’s Capital Account balance (and the amount it is required to restore) in applying the provisions of this paragraph (h), the anticipated adjustments, allocations and distributions described in Treasury Regulation § 1.704-1(b) (2) (ii) (d)(4), (5) and (6) shall be taken into account, and each Partner shall be deemed obligated to restore its deficit Capital Account balance to the extent of its share of Partnership Minimum Gain and Partner Nonrecourse Minimum Gain, if any.

  • If during any Fiscal Year there is a net decrease in either Company Minimum Gain or Member Nonrecourse Minimum Gain, then, notwithstanding any other provision of this Exhibit B, each Member shall receive such special allocation of items of Company income and gain as are required in order to conform to Treasury Regulation Section 1.704-2.

  • Section l.704-2(b)(2)), and Member Nonrecourse Minimum Gain (within the meaning of Treas.

  • In exercising its discretion under this Section, the Board shall take into account future Regulatory Allocations under Sections 5.3.1 and 5.3.2 that, although not yet made, are likely to offset other Regulatory Allocations previously made under Sections 5.3.5 and 5.3.6 and/or distributions of the Company which are included in a Member's share of the Company's Minimum Gain or Member Nonrecourse Minimum Gain.


More Definitions of Nonrecourse Minimum Gain

Nonrecourse Minimum Gain of the Partnership shall mean the amount of "minimum gain" of the Partnership that is attributable to Nonrecourse Liabilities (as determined under section 1.704-2(b)(2) of the Regulations). A Partner's share of such "NONRECOURSE MINIMUM GAIN" shall be calculated in accordance with the provisions of section 1.704-2(g) of the Regulations.
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Related to Nonrecourse Minimum Gain

  • 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).

  • 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).

  • Partnership Minimum Gain has the meaning set forth in Regulations Section 1.704-2(b)(2), and the amount of Partnership Minimum Gain, as well as any net increase or decrease in Partnership Minimum Gain, for a Partnership Year shall be determined in accordance with the rules of Regulations Section 1.704-2(d).