Partner Nonrecourse Debt definition

Partner Nonrecourse Debt has the meaning set forth in Treasury Regulation Section 1.704-2(b)(4).

Partner Nonrecourse Debt shall have the meaning set forth in Regulations Section 1.704-2(b)(4).

Partner Nonrecourse Debt means the same as the term “partner nonrecourse debt” set forth in Regulations Section 1.704-2(b)(4).

Examples of Partner Nonrecourse Debt in a sentence

• Partner Nonrecourse Deductions for any taxable period shall be allocated 100% to the Partner that bears the Economic Risk of Loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section 1.704-2(i).

• If more than one Partner bears the Economic Risk of Loss with respect to a Partner Nonrecourse Debt, such Partner Nonrecourse Deductions attributable thereto shall be allocated between or among such Partners in accordance with the ratios in which they share such Economic Risk of Loss.

• If more than one Partner bears the Economic Risk of Loss with respect to a Partner Nonrecourse Debt, the Partner Nonrecourse Deductions attributable thereto shall be allocated between or among such Partners in accordance with the ratios in which they share such Economic Risk of Loss.

• Notwithstanding the other provisions of this Tax Addendum, if necessary, the Fund will make special allocations to comply with (a) the chargeback of Partnership Minimum Gain (under Regulations Section 1.704-2(f)), (b) the chargeback of Partner Nonrecourse Debt Minimum Gain (under Regulations Section 1.704-2(i)), and (c) the “qualified income offset” provisions of the Regulations (Section 1.704-1(b)(2)(ii)(d)).

• Any Partner Nonrecourse Deductions for any Partnership Year shall be specially allocated to the Holder(s) who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable, in accordance with Regulations Section 1.704-2(i).

More Definitions of Partner Nonrecourse Debt

Partner Nonrecourse Debt shall have the meaning set forth in Treas. Reg. Section 1.704-2(b)(4).

Partner Nonrecourse Debt. Any nonrecourse debt of the Partnership for which a Partner bears the economic risk of loss, determined in accordance with Treasury Regulation Section 1.704-2(b)(4).

Partner Nonrecourse Debt means a liability as defined in Regulations Section 1.704-2(b)(4).

Partner Nonrecourse Debt means any Company liability to the extent such liability is nonrecourse for purposes of Section 1.1001-2 of the Treasury Regulations with respect to which a Member (or related person within the meaning of Section 1.752-4(b) of the Treasury Regulations) bears the economic risk of loss under Section 1.752-2 of the Treasury Regulations because, for example, the Member or related person is a creditor or guarantor with respect to such liability.

Partner Nonrecourse Debt means a nonrecourse liability of the Trust with respect to which an Owner bears the economic risk of loss, as determined in accordance with Treasury Regulations Section 1.704-2(b)(4).

Partner Nonrecourse Debt has the meaning set forth in Treasury Regulations Section 1.704-2(b)(4), which generally defines "Partner Nonrecourse Debt" as any Partnership liability to the extent such liability is nonrecourse and a Partner (or related Person) bears the economic risk of loss pursuant to Treasury Regulations Section 1.752-2.

Partner Nonrecourse Debt has the meaning set forth in Regulations Sections 1.704-2(b)(4) and 1.704-2(i).