Common use of Minimum Gain Chargeback (Nonrecourse Liabilities) Clause in Contracts

Minimum Gain Chargeback (Nonrecourse Liabilities). If there is a net decrease in Partnership Minimum Gain for any fiscal year with respect to the Partnership (except as a result of the conversion or refinancing of any Nonrecourse Liabilities, certain capital contributions, or a revaluation of Partnership property as further outlined in Regulation Sections 1.704-2(d)(4), (f)(2), or (f)(3)), 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 its share of such net decrease in Partnership Minimum Gain. The items to be so allocated shall be determined in accordance with Regulation Section 1.704-2(f). This Section ‎7(b)(i) is intended to comply with the minimum gain chargeback requirement in said sections of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback (Nonrecourse Liabilities). If there is a net decrease in Partnership Minimum Gain for any Partnership fiscal year with respect to the Partnership (except as a result of the conversion or refinancing of any Nonrecourse LiabilitiesPartnership indebtedness, certain capital contributions, contributions or a revaluation of the Partnership property as further outlined in Regulation Sections 1.704-2(d)(4), (f)(2), ) or (f)(3)), 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 its that Partner's share of such the net decrease in Partnership Minimum Gain. The items to be so allocated shall be determined in accordance with Regulation Section 1.704-2(f). This Section ‎7(b)(i) is intended to comply with the minimum gain chargeback requirement in said sections of the Regulations and shall be interpreted consistently therewith.2