Common use of Minimum Gain Chargeback Clause in Contracts

Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.5, if there is a net decrease in Partnership Minimum Gain during any Company fiscal year, each Member shall be specially allocated items of Company income and gain for such year (and, if necessary, for subsequent years) in accordance with Section 1.704-2(f)(1) of the Treasury Regulations in an amount equal to such Member’s share of the net decrease in Partnership Minimum Gain (determined in accordance with Section 1.704-2(g)(2) of the Treasury Regulations). This Section 6.5(a) is intended to comply with the minimum gain chargeback requirement in the Treasury Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.5Article VI, if there is a net decrease in Partnership Minimum Gain minimum gain (as it corresponds to the definition of “partnership minimum gain” in Treasury Regulations Section 1.704-2(b)(2) and (d)) during any Company fiscal yearFiscal Year, each Member the Members shall be specially allocated items of Company income and gain for such year Fiscal Year (and, if necessary, for subsequent yearsFiscal Years) in accordance with Section 1.704-2(f)(1) of the Treasury Regulations in an amount equal to the portion of such Member’s share of the net decrease in Partnership Minimum Gain (minimum gain, determined in accordance with Treasury Regulations Section 1.704-2(g)(22(f) of the Treasury Regulationsand (g). This Section 6.5(a6.2(b)(i) is intended to comply with the “minimum gain chargeback chargeback” requirement in such section of the Treasury Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding any other provision of in this Section 6.55, if there is a net decrease in Partnership Minimum Gain partnership minimum gain (as defined in Treasury Regulations §§ 1.704-2(b)(2) and (d)) during any Company fiscal yearFiscal Year, each Member the Partners shall be specially allocated items of Company Partnership income and gain for such year Fiscal Year (and, if necessary, for subsequent yearsFiscal Years) in accordance with Section 1.704-2(f)(1) of the Treasury Regulations in an amount equal to the portion of such MemberPartner’s share of the net decrease in Partnership Minimum Gain (partnership minimum gain, determined in accordance with Section Treasury Regulations §§ 1.704-2(g)(22(f) of the Treasury Regulationsand (g). This Section 6.5(a5.2(c)(i) is intended to comply with the minimum gain chargeback requirement in such section of the Treasury Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding any other provision of this Subject to the exceptions set forth in Treasury Regulations Section 6.51.704-2(f), if there is a net decrease in Partnership Minimum Gain during any Company a fiscal yearyear of the Partnership, each Member Partner shall be specially allocated items of Company income and gain for such fiscal year (and, if necessary, for subsequent years) in accordance with Section 1.704-2(f)(1) of the Treasury Regulations in an amount equal to such MemberPartner’s share of the net decrease in Partnership Minimum Gain during such fiscal year (which share of such net decrease shall be determined in accordance with under Treasury Regulations Section 1.704-2(g)(2) of the Treasury Regulations)). This Section 6.5(a) It is intended to comply with the that this Section 7.5.1 shall constitute a “minimum gain chargeback requirement in the chargeback” as provided by Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding any other provision Except as otherwise provided in Section 1.704-2(f) of this Section 6.5the Treasury Regulations, if in the event that there is a net decrease in Partnership the Company Minimum Gain during any Company fiscal taxable year, each Member shall be specially allocated items of Company income and gain for such year (and, if necessary, for subsequent years) in accordance with Section 1.704-2(f)(1) of the Treasury Regulations in an amount equal to such Member’s share of the net decrease in Partnership such Company Minimum Gain (determined during such year in accordance with Section 1.704-2(g)(22(g) of the Treasury Regulations). This Section 6.5(a4.4(e)(iii) is intended to comply with the minimum gain chargeback requirement in of Section 1.704-2(f) of the Treasury Regulations and shall be interpreted consistently consistent therewith.

Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.5, if there is a net decrease in Partnership Minimum Gain during any Company fiscal year, each Member shall be specially allocated items of Company income and gain for such year (and, if necessary, for subsequent years) in accordance with Section 1.704-2(f)(1) of the Treasury Regulations in an amount equal to such Member’s share of the net decrease in Partnership Minimum Gain (determined in accordance with Section 1.704-2(g)(2) of the Treasury Regulations). This Section 6.5(a6.5(A) is intended to comply with the minimum gain chargeback requirement in the Treasury Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.55, if there is a net decrease in Partnership Minimum Gain partnership minimum gain (as defined in Treasury Regulations Section 1.704-2(b)(2) and (d)) during any Company fiscal year, each Member the Members shall be specially allocated items of Company income and gain for such fiscal year (and, if necessary, for subsequent fiscal years) in accordance with Section 1.704-2(f)(1) of the Treasury Regulations in an amount equal to the portion of such Member’s share of the net decrease in Partnership Minimum Gain (partnership minimum gain, determined in accordance with Treasury Regulations Section 1.704-2(g)(22(f) of the Treasury Regulationsand (g). This Section 6.5(a5.2(c)(i) is intended to comply with the minimum gain chargeback requirement in such Section of the Treasury Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.55, if there is a net decrease in Partnership Minimum Gain Company minimum gain (as defined in Treasury Regulations Section 1.704-2(b)(2) and (d)) during any Company fiscal year, each Member the Members shall be specially allocated items of Company income and gain for such fiscal year (and, if necessary, for subsequent fiscal years) in accordance with Section 1.704-2(f)(1) of the Treasury Regulations in an amount equal to the portion of such Member’s share of the net decrease in Partnership Minimum Gain (Company minimum gain, determined in accordance with Treasury Regulations Section 1.704-2(g)(22(f) of the Treasury Regulationsand (g). This Section 6.5(a5.2(b)(i) is intended to comply with the minimum gain chargeback requirement in such Section of the Treasury Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.5, if If there is a net decrease in Partnership Minimum Gain (as defined in Treasury Regulations Section 1.704-2(b)(2)) during any Company fiscal year, each Member shall be specially allocated items of Company income and gain gains in accordance with Treasury Regulations Section 1.704-2(f)(1) for such year (and, if necessary, for subsequent years) in accordance with Section 1.704-2(f)(1) of the Treasury Regulations in an amount equal to such Member’s 's share of the such net decrease in Partnership Minimum Gain (determined in accordance with Treasury Regulations Section 1.704-2(g)(2) of the Treasury Regulations). This Section 6.5(a4(c) is intended to comply with the minimum gain chargeback requirement in the Treasury Regulations Section 1.704-2(f)(1) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding any other provision of this Except as otherwise provided in Treasury Regulations Section 6.51.704-2(f) , if there is a net decrease in Partnership Minimum Gain during “partnership minimum gain” (as defined in Treasury Regulations Section 1.704-2(b)(2)) for any Company fiscal yearFiscal Year, each Member shall be specially allocated items of Company income and gain for such year Fiscal Year (and, if necessary, for subsequent yearsFiscal Years) in accordance with Section 1.704-2(f)(1) of the Treasury Regulations in an amount equal to such that Member’s share of the net decrease in Partnership Minimum Gain (partnership minimum gain, determined in accordance with Treasury Regulations Section 1.704-2(g)(2) of the Treasury Regulations2(g). This Section 6.5(a6.7(a) is intended to comply with the minimum gain chargeback requirement in the Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith. Allocations pursuant to this Section 6.7(a) shall be made in proportion to the respective amounts required to be allocated to each Member pursuant hereto.

Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.56, if there is a net decrease in Partnership Minimum Gain partnership minimum gain (as defined in Treasury Regulations Section 1.704-2(b)(2) and (d)) during any Company fiscal year, each Member the Partners shall be specially allocated items of Company Fund income and gain for such fiscal year (and, if necessary, for subsequent fiscal years) in accordance with Section 1.704-2(f)(1) of the Treasury Regulations in an amount equal to the portion of such MemberPartner’s share of the net decrease in Partnership Minimum Gain (partnership minimum gain, determined in accordance with Treasury Regulations Section 1.704-2(g)(22(f) of the Treasury Regulationsand (g). This Section 6.5(a6.2(c)(i) is intended to comply with the minimum gain chargeback requirement in such Section of the Treasury Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding any other provision of this Except as otherwise provided in Treasury Regulations Section 6.51.704-2, if there is a net decrease in Partnership Minimum Gain during any Company fiscal yearFiscal Period, each Member shall be specially allocated items of Company income and gain for such year Fiscal Period (and, if necessary, for subsequent yearsFiscal Periods) in accordance with Section 1.704-2(f)(1) of the Treasury Regulations in an amount equal to such Member’s 's share of the net decrease in Partnership Minimum Gain (determined in accordance with Section 1.704-2(g)(2) of the Treasury Regulations). This Section 6.5(a) is intended to comply with the minimum gain chargeback requirement in the Treasury Regulations and shall be interpreted consistently therewith.in

Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.53.3, if there is a net decrease in Partnership Minimum Gain partnership minimum gain (as defined in Treasury Regulations Sections 1.704-2(b)(2) and (d)) during any Company fiscal year, each Member Partner shall be specially allocated items of Company Partnership income and gain for such fiscal year (and, if necessary, for subsequent fiscal years) in accordance with Section 1.704-2(f)(1) of the Treasury Regulations in an amount equal to such MemberPartner’s share of the net decrease in Partnership Minimum Gain (partnership minimum gain, determined in accordance with Section Treasury Regulations Sections 1.704-2(g)(22(f) of the Treasury Regulationsand (g). This Section 6.5(a3.3(b)(i) is intended to comply with the minimum gain chargeback requirement in such section of the Treasury Regulations and shall be interpreted consistently therewith.;

Minimum Gain Chargeback. Notwithstanding Except as otherwise provided in Treasury Regulations Section 1.704-2(f), notwithstanding any other provision of this Section 6.513, if there is a net decrease in Partnership Minimum Gain during any Company fiscal yearAllocation Year, each Member shall be specially allocated items of Company income and gain for such year Allocation Year (and, if necessary, for subsequent yearsAllocation Years) in accordance with Section 1.704-2(f)(1) of the Treasury Regulations in an amount equal to such Member’s 's share of the net decrease in Partnership Minimum Gain (Gain, determined in accordance with Section Treasury Regulations Sections 1.704-2(g)(22(f)(6) of the Treasury Regulationsand 1.704-2(j)(2). This Section 6.5(a13(b)(i) is intended to comply with the minimum gain chargeback requirement in the Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.55, if there is a net decrease in Partnership Minimum Gain partnership minimum gain (as defined in Treasury Regulations Section 1.704-2(b)(2) and (d)) during any Company fiscal year, each Member the Members shall be specially allocated items of Company income and gain for such fiscal year (and, if necessary, for subsequent fiscal years) in accordance with Section 1.704-2(f)(1) of the Treasury Regulations in an amount equal to the portion of such Member’s 's share of the net decrease in Partnership Minimum Gain (partnership minimum gain, determined in accordance with Treasury Regulations Section 1.704-2(g)(22(f) of the Treasury Regulationsand (g). This Section 6.5(a5.2(b)(i) is intended to comply with the minimum gain chargeback requirement in such Section of the Treasury Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.5Article V, if there is a net decrease in Partnership Minimum Gain partnership minimum gain (as defined in Treasury Regulations Section 1.704-2(b)(2) and (d)) during any Company fiscal year, each Member the Members shall be specially allocated items of Company partnership income and gain for such fiscal year (and, if necessary, for subsequent fiscal years) in accordance with Section 1.704-2(f)(1) of the Treasury Regulations in an amount equal to the portion of such Member’s share of the net decrease in Partnership Minimum Gain (partnership minimum gain, determined in accordance with Treasury Regulations Section 1.704-2(g)(22(f) of the Treasury Regulationsand (g). This Section 6.5(a5.1.2(a) is intended to comply with the minimum gain chargeback requirement in such section of the Treasury Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.5, if If there is a net decrease in the Partnership Minimum Gain during any Company fiscal yearFiscal Year, each Member shall be specially allocated items of Company income and gain profits for such fiscal year (and, if necessary, for subsequent fiscal years) in accordance with Section 1.704-2(f)(1) of the Treasury Regulations in an amount equal to such Member’s share of the net decrease in the Partnership Minimum Gain (Gain, determined in accordance with Treasury Regulations Section 1.704-2(g)(22(g). The items to be so allocated shall be determined in accordance with Treasury Regulations Sections 1.704-2(f)(6) of the Treasury Regulationsand 1.704-2(j)(2). This Section 6.5(aparagraph 24(a) is intended to comply with the minimum gain chargeback requirement in the Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.5, if there is a net decrease in Partnership Minimum Gain (as defined in the Treasury Regulations) during any Company fiscal year, each Member shall be specially allocated items of Company income and gain for such year (and, if necessary, for subsequent years) in accordance with Section 1.704-2(f)(1) of the Treasury Regulations in an amount equal to such Member’s share of the net decrease in Partnership Minimum Gain (determined in accordance with Section 1.704-2(g)(2) of the Treasury Regulations). This Section 6.5(a6.5(A) is intended to comply with the minimum gain chargeback requirement in the Treasury Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Notwithstanding any other provision of this Section 6.5Agreement, if there is a net decrease in Partnership Minimum Gain during “partnership minimum gain” (as that term is defined in Treasury Regulation Sections 1.704-2(b)(2) and 1.704-2(d)) for any Company fiscal yearFiscal Year, each Member shall shall, in the manner provided in Treasury Regulation Section 1.704-2(f), be specially allocated items of Company income and gain for such year (and, if necessary, for subsequent yearsFiscal Years) in accordance with Section 1.704-2(f)(1) of the Treasury Regulations in an amount equal to such Member’s share of the net decrease in Partnership Minimum Gain (such partnership minimum gain, determined in accordance with Treasury Regulation Section 1.704-2(g)(2) of the Treasury Regulations2(g). This Section 6.5(a6.3(A) is intended to comply with the minimum gain chargeback requirement in the Treasury Regulations Regulation Section 1.704-2(f) and shall be interpreted consistently therewith.