Common use of Minimum Gain Chargeback Clause in Contracts

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section 1.704-2(f), notwithstanding any other provision of this Agreement, if there is a net decrease in Partnership Minimum Gain during any fiscal year, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year (and, if necessary, subsequent fiscal years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Treasury Regulation section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections 1.704-2(f)(6) and 1.704-2(j)(2). This provision is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Regulations Section 1.704-2(f), notwithstanding any other provision of this AgreementArticle 5, if there is a net decrease in Partnership Minimum Gain during any fiscal yearFiscal Year, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year Fiscal Year (and, if necessary, subsequent fiscal yearsFiscal Years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Treasury Regulation section Regulations Section 1.704-2(g). Allocations pursuant to the previous immediately preceding sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Regulations Section 1.704-2(f)(6) and 1.704-2(j)(2). This provision Section 5.04(b)(i) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Regulations Section 1.704-2(f), notwithstanding any other provision of this AgreementArticle V, if there is a net decrease in Partnership Minimum Gain during any fiscal yearFiscal Year, each Partner shall will be specially allocated items of Partnership income and gain for such fiscal year the Fiscal Year (and, if necessary, subsequent fiscal yearsFiscal Years) in an amount equal to such the Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Treasury Regulation section Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall will be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2). This provision Section 5.3(a) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section Regulations Section 1.704-2(f) and shall will be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Regulations Section 1.704-2(f), notwithstanding any other provision of this AgreementArticle 7, if there is a net decrease in Partnership Minimum Gain during any fiscal yearFiscal Year, each Partner shall will be specially allocated items of Partnership income and gain for such fiscal year the Fiscal Year (and, if necessary, subsequent fiscal yearsFiscal Years) in an amount equal to such the Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Treasury Regulation section Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall will be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2). This provision Section 7.3(a) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section Regulations Section 1.704-2(f) and shall will be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Regulations Section 1.704-2(f), notwithstanding any other provision of this AgreementArticle 6, if there is a net decrease in Partnership Minimum Gain during any fiscal yearFiscal Year, each Partner Member shall be specially allocated items of Partnership Company net income and gain for such fiscal year Fiscal Year (and, if necessary, subsequent fiscal yearsFiscal Years) in an amount equal to such PartnerMember’s share of the net decrease in Partnership Minimum Gainpartnership minimum gain, determined in accordance with Treasury Regulation section Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2). This provision Section 6.2(a) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section 1.704-2(f), notwithstanding Notwithstanding any other provision of this AgreementArticle IV, if there is a net decrease in Partnership Minimum Gain during any fiscal year, then, subject to the exceptions set forth in Treasury Regulations Sections 1.704-2(f)(2), (3), (4) and (5), each Partner shall be specially allocated items of Partnership income and gain for such fiscal year (and, if necessary, subsequent fiscal years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, Gain determined in accordance with Treasury Regulation section Section 1.704-2(g). Allocations pursuant to ) of the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant theretoTreasury Regulations. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Section 1.704-2(f)(62(f) and 1.704-2(j)(2)of the Treasury Regulations. This provision Section 4.06(a)(i) is intended to comply with the minimum gain chargeback requirement in such Section of the Treasury Regulation section 1.704-2(f) Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Section 1.704-2(f), notwithstanding any other provision of this AgreementSection 5.1, if there is a net decrease in Partnership Minimum Gain during any fiscal yearAdjustment Period, each Partner shall Member will be specially allocated items of Partnership Company income and gain for such fiscal year the period (and, if necessary, subsequent fiscal yearsperiods) in an amount equal to such Partnerthat Member’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Treasury Regulation section Section 1.704-2(g). Allocations pursuant to the previous sentence shall will be made in proportion to the respective amounts required to be allocated to each Partner pursuant theretoMember. The items to be so allocated shall will be determined in accordance with Treasury Regulation sections Section 1.704-2(f)(6) and 1.704-2(j)(2). This provision subsection is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section Section 1.704-2(f) and shall may be interpreted consistently therewithwith it.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section To the extent required by Section 1.704-2(f), notwithstanding any other provision ) of this Agreementthe Treasury Regulations, if there is a net decrease in Partnership Minimum Gain during any “partnership minimum gain” (within the meaning of Section 1.704-2(b)(2) of the Treasury Regulations) in a fiscal year, then each Partner Member shall be specially allocated items of Partnership income and gain for such (including gross income) arising during that fiscal year (and, and if necessary, necessary subsequent fiscal years) in an amount ), equal to such PartnerMember’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Treasury Regulation section 1.704-2(g)partnership minimum gain. Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Sections 1.704-2(f)(6) and 1.704-2(j)(2). This provision Section 5.1(b)(i) is intended to comply with the minimum gain chargeback requirement in requirements of Treasury Regulation section Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Regulations Section 1.704-2(f), notwithstanding any other provision of this Agreement, if there is a net decrease in Partnership Minimum Gain during any fiscal yearFiscal Year, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year Fiscal Year (and, if necessary, subsequent fiscal yearsFiscal Years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Treasury Regulation section Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2). This provision Section 6.03(a) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation Regulations section 1.704-2(f), notwithstanding any other provision of this Agreement, if there is a net decrease in Partnership Minimum Gain during any fiscal year, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year (and, if necessary, subsequent fiscal years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Treasury Regulation Regulations section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation Regulations sections 1.704-2(f)(6) and 1.704-2(j)(2). This provision is intended to comply with the minimum gain chargeback requirement in Treasury Regulation Regulations section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Regulations Section 1.704-2(f), notwithstanding any other provision of this Agreement2, if there is a net decrease in Partnership Minimum Gain during any fiscal yearFiscal Period, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year Fiscal Period (and, if necessary, subsequent fiscal yearsFiscal Periods) in an amount equal to such Partner’s share of the net decrease in such Partnership Minimum Gain, as determined in accordance with Treasury Regulation section Regulations Section 1.704-2(g)2. Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner the Partners pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Regulations Section 1.704-2(f)(6) and 1.704-2(j)(2)2. This provision Section 6.2(c)(i) is intended to comply with the minimum gain chargeback requirement requirements in such Treasury Regulation section 1.704-2(f) Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Section 1.704-2(f)) of the Treasury Regulations, and notwithstanding any other provision of this AgreementAppendix, if there is a net decrease in Partnership Minimum Gain during any fiscal yearPartnership Fiscal Year, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year Fiscal Year (and, if necessary, subsequent fiscal years) Fiscal Years), in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Treasury Regulation section Regulations Section 1.704-2(g). Allocations pursuant to the previous prior sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2). This provision Section 2(a) is intended to comply with the minimum gain chargeback requirement set forth in Treasury Regulation section Section 1.704-2(f) of the Treasury Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Regulations Section 1.704-2(f), notwithstanding any other provision of this AgreementArticle 3, if there is a net decrease in Partnership Company Minimum Gain during any fiscal yearFiscal Year, each Partner shall Member will be specially allocated items of Partnership Company income and gain for such fiscal year the Fiscal Year (and, if necessary, subsequent fiscal yearsFiscal Years) in an amount equal to such Partnerthe Member’s share of the net decrease in Partnership Company Minimum Gain, determined in accordance with Treasury Regulation section Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall will be made in proportion to the respective amounts required to be allocated to each Partner Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(220)(2). This provision Section 3.3(a) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section Regulations Section 1.704-2(f) and shall will be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Regulations Section 1.704-2(f), notwithstanding any other provision of this AgreementArticle 5, if there is a net decrease in Partnership Minimum Gain during any fiscal yearFiscal Year, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year Fiscal Year (and, if necessary, subsequent fiscal yearsFiscal Years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Treasury Regulation section Regulations Section 1.704-2(g). 29 Allocations pursuant to the previous immediately preceding sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Regulations Section 1.704-2(f)(6) and 1.704-2(j)(2). This provision Section 5.04(b)(i) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section 1.704-2(f), notwithstanding any other provision of this Agreement, if If there is a net decrease in Partnership Minimum Gain during any fiscal yearAllocation Year, each Partner and Unit Holder shall be specially allocated items of Partnership income and gain for such fiscal year Allocation Year (and, if necessary, subsequent fiscal yearsAllocation Years) in proportion to, and to the extent of, an amount equal to such Partner’s and/or Unit Holder’s share of the net decrease in Partnership Minimum Gain, Gain determined in accordance with Treasury Regulation section Regulations Section 1.704-2(g2(g)(2). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be so allocated to each Partner and/or Unit Holder pursuant thereto. The items to be so allocated shall will be determined in accordance with Treasury Regulation sections Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2). This provision Section 3.3(a) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Section 1.704-2(f), notwithstanding any other provision of this AgreementSection 5, if there is a net decrease in Partnership Minimum Gain during any fiscal yearFiscal Year, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year Fiscal Year (and, if necessary, subsequent fiscal yearsFiscal Years) in an amount equal to such Partner’s 's share of the net decrease in Partnership Minimum Gain, determined in accordance with Treasury Regulation section Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Sections 1.704-2(f)(6) and 1.704-2(j)(2). This provision Section 5.3(a) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Section 1.704-2(f)) of the Treasury Regulations, notwithstanding any other provision of this AgreementSection 5, if there is a net decrease in Partnership Minimum Gain during any fiscal yearFiscal Year, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year Fiscal Year (and, if necessary, subsequent fiscal yearsFiscal Years) in an amount equal to such Partner’s 's share of the net decrease in Partnership Minimum Gain, determined in accordance with Treasury Regulation section Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections 1.704-Sections 1.704- 2(f)(6) and 1.704-2(j)(2)) of the Treasury Regulations. This provision Section 5.4.1 is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section Section 1.704-2(f) of the Treasury Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Section 1.704-2(f), notwithstanding any other provision of this Agreement, if there is a net decrease in Partnership Minimum Gain partnership minimum gain (as defined in the Code) during any fiscal yearFiscal Year, each Partner Member shall be specially allocated items of Partnership Company income and gain for such fiscal year Fiscal Year (and, if necessary, subsequent fiscal yearsFiscal Years) in an amount equal to such Partner’s Member's share of the net decrease in Partnership Minimum Gainpartnership minimum gain, determined in accordance with Treasury Regulation section Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Sections 1.704-2(f)(6) and 1.704-2(j)(2). This provision Section 4.1(c)(i) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Regulations Section 1.704-2(f), notwithstanding any other provision of this AgreementArticle 4, if there is a net decrease in Partnership Minimum Gain during any fiscal yearPartnership taxable period, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year taxable period (and, if necessary, subsequent fiscal yearstaxable periods) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Treasury Regulation section 1.704-2(gRegulations Section 1.7042(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant theretoPartner. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(220)(2). This provision Section 43(b) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Section 1.704-2(f)) of the Treasury Regulations, notwithstanding any other provision provisions of this AgreementArticle 4, if there is a net decrease in Partnership Minimum Gain during any fiscal yearAllocation Year, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year Allocation Year (and, if necessary, subsequent fiscal yearsAllocation Years) in an amount equal to such Partner’s 's share of the net decrease in Partnership Minimum Gain, determined in accordance with Treasury Regulation section Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Sections 1.704-2(f)(62(f) (6) and 1.704-2(j)(2)) of the Treasury Regulations. This provision Section 4.03(a) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section Section 1.704-2(f) of the Treasury Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Regulations Section 1.704-2(f), notwithstanding any other provision of this Agreement‎Article 5, if there is a net decrease in Partnership Minimum Gain during any fiscal yearFiscal Year, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year Fiscal Year (and, if necessary, subsequent fiscal yearsFiscal Years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Treasury Regulation section Regulations Section 1.704-2(g). Allocations pursuant to the previous immediately preceding sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Regulations Section 1.704-2(f)(6) and 1.704-2(j)(2). This provision ‎Section 5.04(b)(i) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section 1.704-2(f), notwithstanding Notwithstanding any other provision of this AgreementArticle V, subject to the exceptions set forth in Treasury Regulations Section 1.704-2(f), if there is a net decrease in Partnership Minimum Gain during any fiscal yearFiscal Year, each Partner the Partners shall be specially allocated items of Partnership income and gain for such fiscal year Fiscal Year (and, if necessary, subsequent fiscal yearsFiscal Years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Treasury Regulation section Regulations Section 1.704-2(g2(g)(2). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Regulations Section 1.704-2(f)(6) and 1.704-2(j)(22(f). This provision Section 5.2(a)(i) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section Section 1.704-2(f) of the Treasury Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Regulations Section 1.704-2(f), notwithstanding the provisions of Section 3.2, or any other provision of this AgreementArticle III, if there is a net decrease in Partnership Minimum Gain during any fiscal yearFiscal Year, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year (and, if necessary, subsequent fiscal years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, as determined in accordance with under Treasury Regulation section Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2). This provision Section 3.3(a)(i) is intended to comply with the minimum gain chargeback requirement in requirements of Treasury Regulation section Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Regulations Section 1.704-2(f), notwithstanding any other provision of this AgreementArticle VII, if there is a net decrease in Partnership Minimum Gain during any fiscal yearFiscal Year, each Partner shall will be specially allocated items of Partnership income and gain for such fiscal year the Fiscal Year (and, if necessary, subsequent fiscal yearsFiscal Years) in an amount equal to such the Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Treasury Regulation section Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall will be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2). This provision Section 7.3(a) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section Regulations Section 1.704-2(f) and shall will be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section §1.704-2(f)) of the Treasury Regulations, notwithstanding any other provision of this AgreementArticle III, if there is a net decrease in Partnership Fund Minimum Gain during any fiscal yearFiscal Year, each Partner shall be specially allocated items of Partnership Fund income and gain for such fiscal year Fiscal Year (and, if necessary, subsequent fiscal yearsFiscal Years) in an amount equal to such Partner’s share of the net decrease in Partnership Fund Minimum Gain, determined in accordance with Treasury Regulation section Regulations §1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections §§1.704-2(f)(6) and 1.704-2(j)(2)1.704(j)(2) of the Treasury Regulations. This provision Section 3.7.2 is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section §1.704-2(f) of the Treasury Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Section 1.704-2(f), notwithstanding any other provision the provisions of this AgreementArticle 4, if there is a net decrease in the Partnership Minimum Gain during any fiscal yeartax year of the Partnership, each Partner shall be specially allocated items of Partnership income and gain the Partnership’s profits for such fiscal year (and, if necessary, subsequent fiscal years) in an amount equal to such Partner’s share of the net decrease in Partnership the Partnership’s Minimum Gain, as determined in accordance with under Treasury Regulation section Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Sections 1.704-2(f)(6) and 1.704-2(j)(21.704-(j)(2). This provision Section 4.4(a) is intended to comply with the qualify as a “minimum gain chargeback requirement in chargeback” within the meaning of Treasury Regulation section Section 1.704-2(f2(1) and which shall be interpreted consistently therewithcontrolling in the event of a conflict between such Treasury Regulation and this Section 4.4(a).

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Section 1.704-2(f)) of the Treasury Regulations, notwithstanding any other provision of this AgreementSection 1.2, if there is a net decrease in Partnership Minimum Gain during any fiscal year, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year (and, if necessary, subsequent fiscal years) in an amount equal to the portion of such Partner’s 's share of the net decrease in Partnership Minimum Gain, determined in accordance with Treasury Regulation section Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Sections 1.704-2(f)(6) and 1.704-2(j)(2)) of the Treasury Regulations. This provision Section 1.2(c)(i) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section Section 1.704-2(f) of the Treasury Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Regulations Section 1.704-2(f), notwithstanding any other provision of this Agreement2, if there is a net decrease in Partnership Minimum Gain during any fiscal yearFiscal Period, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year Fiscal Period (and, if necessary, subsequent fiscal yearsFiscal Periods) in an amount equal to such Partner’s 's share of the net decrease in such Partnership Minimum Gain, as determined in accordance with Treasury Regulation section Regulations Section 1.704-2(g)2. Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner the Partners pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Regulations Section 1.704-2(f)(6) and 1.704-2(j)(2)2. This provision Section 6.2(c)(i) is intended to comply with the minimum gain chargeback requirement requirements in such Treasury Regulation section 1.704-2(f) Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Regulations Section 1.704-2(f), notwithstanding any other provision of this AgreementSection 11, if there is a net decrease in Partnership Minimum Gain during any fiscal yearAllocation Period, each Partner shall will be specially allocated items of Partnership income and gain for such fiscal year the Allocation Period (and, if necessary, subsequent fiscal yearsAllocation Period) in an amount equal to such the Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Treasury Regulation section Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall will be determined in accordance with Treasury Regulation sections Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2). This provision Section 11(c)(i) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section Regulations Section 1.704-2(f) and shall will be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Regulations Section 1.704-2(f), notwithstanding any other provision of this AgreementArticle V, if there is a net decrease in Partnership Minimum Gain during any fiscal yearFiscal Year, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year Fiscal Year (and, if necessary, subsequent fiscal yearsFiscal Years) in an amount equal to such PartnerPerson’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Treasury Regulation section Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2). This provision Section 5.4(a) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Section 1.704-2(f), and notwithstanding any other provision of in this AgreementArticle X, if there is a net decrease in Partnership Company Minimum Gain during any fiscal yearFiscal Year, each Partner Member shall be specially allocated items of Partnership Company income and gain for such fiscal year (and, if necessary, subsequent fiscal years) in an amount equal to such PartnerMember’s share of the net decrease in Partnership Company Minimum Gain, determined in accordance with Treasury Regulation section Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner Member pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Regulations Sections 1.704-2(f)(62(f) and 1.704-1.704- 2(j)(2). This provision Section 10.7 is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section Section 1.704-2(f)) of the Treasury Regulations, notwithstanding any other provision of this AgreementAgreement to the contrary, if there is a net decrease in Partnership Minimum Gain during any fiscal Partnership taxable year, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year (and, if necessary, subsequent fiscal years) in an amount equal to such Partner’s 's share of the net decrease in Partnership Minimum Gain, Gain determined in accordance with Treasury Regulation section Section 1.704-2(g)) of the Treasury Regulations. Allocations made pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Sections 1.704-2(f)(6) and 1.704-2(j)(2)) of the Treasury Regulations. This provision is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section Section 1.704-2(f) of the Treasury Regulations and shall be interpreted consistently consistent therewith.

Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation section 1.704-Regulations Section l.704- 2(f), notwithstanding any other provision of this AgreementArticle 7, if there is a net decrease in Partnership Minimum Gain during any fiscal yearFiscal Year, each Partner shall will be specially allocated items of Partnership income and gain for such fiscal year the Fiscal Year (and, if necessary, subsequent fiscal yearsFiscal Years) in an amount equal to such the Partner’s 's share of the net decrease in Partnership Minimum Gain, determined in accordance with Treasury Regulation section 1.704Regulations Section l.704-2(g). Allocations pursuant to the previous sentence shall will be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Treasury Regulation sections Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2). This provision Section 7.3(a) is intended to comply with the minimum gain chargeback requirement in Treasury Regulation section 1.704Regulations Section l.704-2(f) and shall will be interpreted consistently therewith.