Minimum Gain Chargeback definition

Minimum Gain Chargeback shall have the meaning set forth in Section 6.1(d)(l) hereof.

Minimum Gain Chargeback is defined in Section 5.1(d)(1) hereof.

Minimum Gain Chargeback shall have the meaning set forth in Section 6.1(d)(i).

Examples of Minimum Gain Chargeback in a sentence

• The amount that would otherwise be subject to the Member Minimum Gain Chargeback requirement is added to the Member’s share of Company Minimum Gain.

• The following special allocations shall be made in the following order: (a) Minimum Gain Chargeback.

• Any Qualified Income Offset, Gross Income Allocation, Nonrecourse Deduction, Member Nonrecourse Deductions, Member Minimum Gain Chargeback, Minimum Gain Chargeback, Code Section 704(c) allocations, or other amount shall be specially allocated under Sections 5.04, 5.05, 5.06, 5.07, 5.08, 5.09, 5.10, 5.11 and 5.12 before any other allocations, and the Minimum Gain Chargebacks shall be the first allocations made.

• In accordance with Treasury Regulation § 1.704- 2(i)(4), a Member is not subject to this Member Minimum Gain Chargeback requirement to the extent the net decrease in Member Minimum Gain arises because the liability ceases to be Member Nonrecourse Debt due to a conversion, refinancing or other change in the debt instrument that causes it to be partially or wholly a Nonrecourse Debt.

• The amount that would otherwise be subject to the Member Minimum Gain Chargeback is added to the Member’s share of Company Minimum Gain.

More Definitions of Minimum Gain Chargeback

Minimum Gain Chargeback shall have the meaning ascribed thereto in Section 1.704-2(b)(2) of the Treasury Regulations, as it applies to the Company.

Minimum Gain Chargeback is defined in Section 7.5.3.

Minimum Gain Chargeback shall have the meaning attributed to it in Section 6.4(e)(3). “Net Percentage Rent”, for a Fiscal Year, shall mean an amount equal to (i) gross Percentage Rent for such Fiscal Year, reduced by (ii) Operating Expenditures for such Fiscal year multiplied by a fraction the numerator of which is gross Percentage Rent for such Fiscal Year and the denominator of which is gross Operating Revenues for such Fiscal Year (reduced by Additional Rents and the proceeds of construction financing or refinancing for such Fiscal Year).

Minimum Gain Chargeback. Allocations. Except as otherwise provided in Regulation § 1.704-2(f), and notwithstanding any other provision of this Section 8, if there is a net decrease in Partnership Minimum Gain during any Partnership taxable year, each Partner shall be specially allocated items of Partnership income and gain for such taxable year (and, if necessary, subsequent taxable years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulation §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 Regulation §§1.704-2(f)(6) and 1.704-2(j)(2). This Section 8.9 is intended to comply with the minimum gain chargeback requirement in Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback is defined in SECTION 4.6.

Minimum Gain Chargeback. Allocations. Except as otherwise provided in Regulation §1.704-2(f), and notwithstanding any other provision of this Section , if there is a net decrease in Company Minimum Gain during any Company taxable year, each Member shall be specially allocated items of Company income and gain for such taxable year (and, if necessary, subsequent taxable years) in an amount equal to such Member’s share of the net decrease in Company Minimum Gain, determined in accordance with Regulation §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 Member pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §§1.704-2(f)(6) and 1.704-2(j)(2). This Section is intended to comply with the minimum gain chargeback requirement in Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback shall have the meaning set forth in Section 6.1(d)(l) hereof. 8 13 "Net Financing Proceeds" shall mean the cash proceeds received by the Partnership in connection with any borrowing by or on behalf of the Partnership (whether or not secured), or distributed to the Partnership in respect of any such borrowing by any Subsidiary Entity, after deduction of all costs and expenses incurred by the Partnership in connection with such borrowing, and after deduction of that portion of such proceeds used to repay any other indebtedness of the Partnership, or any interest or premium thereon.