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Subject: partnership minimum gain; partner nonrecourse debt minimum gain law Пожалуйста, помогите перевести.
partnership minimum gain; partner nonrecourse debt minimum gainВыражение встречается в следующем контексте:
4.1.Allocations of Profit and Loss.(from Operating Agreement)
If, for a fiscal year, there is an increase in the amount by which any liability of the Company exceeds the assets of the Company which are subject to such liability (as determined under Section 1.704-2(d)(2)(ii) of the Regulations), such that there is a net increase in "partnership minimum gain" or "partner nonrecourse debt minimum gain" of the Company, then (i) any "nonrecourse deductions" related to an increase "partnership minimum gain" for such year shall be allocated between the Members pro rata, based upon their Percentage Interests, and (ii) any "partner nonrecourse deductions" related to an increase in "partner nonrecourse debt minimum gain" shall be allocated to the Member who bears the economic risk of loss with respect to the liability to which such "partner nonrecourse deductions" are attributable. If, for any fiscal year, there is a decrease in the amount by which any liability of the Company exceeds the assets of the Company subject to such liability (as determined under Section 1.704-2(d)(2)(ii) of the Regulations), then (i) each Member shall be specially allocated gross income in the amount of such Member's share of any net decrease in "partnership minimum gain" in accordance with Section 1.704-2(f) of the Regulations and (ii) each Member shall be specially allocated gross income in the amount of such Member's share of any net decrease in "partner nonrecourse debt minimum gain" in accordance with Section 1.704-2(i)(4) of the Regulations. Заранее спасибо
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