Common use of Special Allocation Rules Clause in Contracts

Special Allocation Rules. (a) For purposes of this Agreement, a loss or allocation (or item thereof) is attributable to non-recourse debt which is secured by Partnership property to the extent of the excess of the outstanding principal balance of such debt (excluding any portion of such principal balance which would not be treated as an amount realized under Internal Revenue Code Section 1001 and Paragraph (a) of Section 1.1001-2 if such debt were foreclosed upon over the adjusted basis of such property. This excess is herein defined as "Minimum Gain (whether taxable as capital gain or as ordinary income) as more explicitly set forth in Treasury Regulation T.704 l(b)(4)(iv)(c). Notwithstanding any other provision of Article V, the allocation of loss or deduction (or item thereof, attributable to non-recourse debt which is secured by Partnership property will be allowed only to the extent that such allocation does not cause the sum of the deficit capital account balances of the Limited Partners receiving such allocations to exceed the minimum gain determined at the end of the Partnership able year to which the allocations relate. The balance of such losses shall be allocated to the General Partners. Any Limited Partner with a deficit capital account balance resulting in whole or in part from allocations of loss or deduction (or item thereof) attributable to non-recourse debt which is secured by Partnership property shall, to the extent possible, be allocated income or gain (or item thereof) in an amount not less than the minimum gain at a time no later than the time at which the minimum gain is reduced below the sum if such deficit capital account balances. This section is intended and shall be interpreted to comply with the requirements of Treasury Regulation Section 1.704-l(b)(4)(iv)(e).

Special Allocation Rules. (a) 7.5.1. For purposes of this Agreement, a loss or allocation (or item thereof) is attributable to non-recourse debt which is secured by Partnership Company property to the extent of the excess of the outstanding principal balance of such the debt (excluding any portion of such the principal balance which would not be treated as an amount realized under Internal Revenue Code Section 1001 of the Code and Paragraph (a) of Treasury Regulation Section 1.1001-2 if such the debt were foreclosed upon upon) over the adjusted basis of such the property. This excess is herein defined as called "Minimum Gain Gain" (whether taxable as capital gain or as ordinary income) as more explicitly set forth in Treasury Regulation T.704 l(b)(4)(iv)(cSections 1.704-2(b)(2) and 1.704- 2(d). Notwithstanding any other provision of Article V7, the allocation of loss or deduction (or item thereof, ) attributable to non-recourse debt which is secured by Partnership Company property will be allowed only to the extent that such the allocation does not cause the sum of the deficit capital account Capital Account balances of the Limited Partners Members receiving such the allocations to exceed the minimum gain Minimum Gain determined at the end of the Partnership able Company's taxable year to which the allocations relate. The balance of such the losses shall be allocated to the General PartnersManager. Any Limited Partner Member with a deficit capital account Capital Account balance resulting in whole or in part from allocations of loss or deduction (or item thereof) attributable to non-recourse debt which is secured by Partnership Company property shall, to the extent possible, be allocated income or gain (or item thereof) in an amount not less than the minimum gain Minimum Gain at a time no later than the time at which the minimum gain Minimum Gain is reduced below the sum if such of the deficit capital account Capital Account balances. This section is intended and shall be interpreted to comply with the requirements of Treasury Regulation Section 1.704-l(b)(4)(iv)(e2(f).

Special Allocation Rules. (a) For purposes of this Agreement, a loss or allocation (or item thereof) is attributable to non-recourse debt which is secured by Partnership property to the extent of the excess of the outstanding principal balance of such debt (excluding any portion of such principal balance which would not be treated as an amount realized under Internal Revenue Code Section 1001 and Paragraph (a) of Section 1.1001-2 2) if such debt were foreclosed upon over the adjusted basis of such property. This excess is herein defined as "“Minimum Gain Gain” (whether taxable as capital gain or as ordinary income) as more explicitly set forth in Treasury Regulation T.704 l(b)(4)(iv)(c)1.704-2. Notwithstanding any other provision of Article V5, the allocation of loss or deduction (or item thereof, attributable to non-recourse debt which is secured by Partnership property will be allowed only to the extent that such allocation does not cause the sum of the deficit capital account balances of the Limited Partners receiving such allocations to exceed the minimum gain determined at the end of the Partnership able year to which the allocations relate. The balance of such losses shall be allocated to the General Partners. Any Limited Partner with a deficit capital account balance resulting in whole or in part from allocations of loss or deduction (or item thereof) attributable to non-recourse debt which is secured by Partnership property shall, to the extent possible, be allocated income or gain (or item thereof) in an amount not less than the minimum gain at a time no later than the time at which the minimum gain is reduced below the sum if of such deficit capital account balances. This section is intended and shall be interpreted to comply with the requirements of Treasury Regulation Section 1.704-l(b)(4)(iv)(e2(f).

Special Allocation Rules. (a) 7.5.1 For purposes of this Agreement, a loss or allocation (or item thereof) is attributable to non-recourse debt which is secured by Partnership Company property to the extent of the excess of the outstanding principal balance of such the debt (excluding any portion of such the principal balance which would not be treated as an amount realized under Internal Revenue Code Section 1001 of the Code and Paragraph (a) of Treasury Regulation Section 1.1001-2 if such the debt were foreclosed upon upon) over the adjusted basis of such the property. This excess is herein defined as "called “Minimum Gain Gain” (whether taxable as capital gain or as ordinary income) as more explicitly set forth in Treasury Regulation T.704 l(b)(4)(iv)(cSections 1.704-2(b)(2) and 1.704-2(d). Notwithstanding any other provision of Article V7, the allocation of loss or deduction (or item thereof, ) attributable to non-recourse debt which is secured by Partnership Company property will be allowed only to the extent that such the allocation does not cause the sum of the deficit capital account Capital Account balances of the Limited Partners Members receiving such the allocations to exceed the minimum gain Minimum Gain determined at the end of the Partnership able Company’s taxable year to which the allocations relate. The balance of such the losses shall be allocated to the General PartnersManager. Any Limited Partner Member with a deficit capital account Capital Account balance resulting in whole or in part from allocations of loss or deduction (or item thereof) attributable to non-recourse debt which is secured by Partnership Company property shall, to the extent possible, be allocated income or gain (or item thereof) in an amount not less than the minimum gain Minimum Gain at a time no later than the time at which the minimum gain Minimum Gain is reduced below the sum if such of the deficit capital account Capital Account balances. This section is intended and shall be interpreted to comply with the requirements of Treasury Regulation Section 1.704-l(b)(4)(iv)(e2(f).

Special Allocation Rules. (a) For purposes of this Agreement, a loss or allocation (or item thereof) is attributable to non-recourse debt which is secured by Partnership Company property to the extent of the excess of the outstanding principal balance of such debt (excluding any portion of such principal balance which would not be treated as an amount realized under Internal Revenue Code Section 1001 and Paragraph (a) of Code Section 1.10011.001-2 if such debt were foreclosed upon upon) over the adjusted basis of such property. This excess is herein defined as "Minimum Gain Gain" (whether taxable as capital gain or as ordinary income) as more explicitly set forth in Treasury Regulation T.704 l(b)(4)(iv)(c1.704-1(b)(4)(iv)(c). Notwithstanding any other provision of Article V, the allocation of loss or deduction (or item thereof, ) attributable to non-recourse non -recourse debt which is secured by Partnership Company property will be allowed only to the extent that such allocation does not cause the sum of the deficit capital account Capital Account balances of the Limited Partners Members receiving such allocations to exceed the minimum gain determined at the end of the Partnership able Company taxable year to which the allocations relate. The balance of such losses shall be allocated to the General Partners. Any Limited Partner Member with a deficit capital account Capital Account balance resulting in whole or in part from allocations of loss or deduction (or item thereof) attributable to non-recourse debt which is secured by Partnership Company property shall, to the extent possible, be allocated income or gain (or item thereof) in an amount not less than the minimum gain at a time no later than the time at which the minimum gain is reduced below the sum if of such deficit capital account balances. This section Section is intended and shall be interpreted to comply with the requirements of Treasury Regulation Section 1.704-l(b)(4)(iv)(e1(b)(4)(iv)(e).