ADDITIONAL SPECIAL ALLOCATIONS. Notwithstanding anything to the contrary in SECTION 7.1 or elsewhere in this Agreement, a portion of any Net Income or Net Loss allocable to the Partnership from certain partnerships in which it holds interests that would otherwise be allocable to the holder of the General Partnership Units shall instead be allocable to the other Partners in proportion to their respective Percentage Interests.
ADDITIONAL SPECIAL ALLOCATIONS a) This Agreement shall be deemed to contain (i) a qualified income offset as described in Section 1.704-1(b)(2)(ii)(d)(4), (5) or (6) of the Treasury Regulations; (ii) a minimum gain chargeback as provided in Section 1.704-2(f) of the Treasury Regulations; and (iii) a partner minimum gain chargeback in accordance with Section 1.704-2(i) of the Treasury Regulations. (b) Certificateholder Nonrecourse Deductions. Any Certificateholder Nonrecourse Deductions shall be allocated to the Lease Trust Certificateholder that bears the economic risk of loss with respect to the Certificateholder Nonrecourse Debt to which such Certificateholder Nonrecourse Deductions are attributable in accordance with Section 1.704-2(i)(1) of the Treasury Regulations.