Non-Recourse Deductions. Non-Recourse Deductions for any Fiscal Year shall be allocated to the Members in accordance with their Percentage Interests.
Non-Recourse Deductions. Non-Recourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines that the Partnership’s Non-Recourse Deductions should be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Non-Recourse Deductions. Non-Recourse Deductions for any Fiscal Year or other period shall be allocated 99% to the Members in proportion to their Units and 1% to the Managers and each Member’s and the Manager’s share of Excess Non-recourse Liabilities shall be in the same proportion.
Non-Recourse Deductions. Non-recourse deductions (as described in Section 1.704-2(b) of the Treasury Regulations) for any Fiscal Year or other period shall be allocated to the Members in accordance with their relative Percentage Interests.
Non-Recourse Deductions. Non-recourse deductions (as defined in Regulations Section 1.704-2(b)(1)) for any taxable year or other period shall be allocated to the Preferred Partners pro rata in accordance with their respective Preferred Units. The amount of non-recourse deductions and excess non-recourse liabilities shall be determined in accordance with Regulations Section 1.704-2(c).
Non-Recourse Deductions. Any "Non-Recourse Deductions" as defined in Regulations Section 1.704-2(c) for any fiscal year or other period shall be specially allocated as items of loss in the manner provided in Regulations Section 1.704-2(j)(1)(ii).
Non-Recourse Deductions. Non-Recourse Deductions for any Fiscal Year shall be allocated to the Limited Partners in accordance with their Percentage Interests.
Non-Recourse Deductions. Non-recourse deductions (as defined in Treasury Regulations Section 1.704-2(b)(1)) shall be allocated in accordance with the Members’ Percentage Interests, pursuant to Treasury Regulations Section 1.704-2(e)(2). Non-recourse deductions attributable to Member non-recourse debt (as defined in Treasury Regulations Section 1.704-2(b)(4)) shall be allocated to the Member or Members that bear the economic risk of loss for such debt in accordance with Treasury Regulations Section 1.704-2(i)(1).
Non-Recourse Deductions. Non-recourse Deductions for any fiscal year or other period shall be allocated to the Partners pro rata based upon their relative Percentage Interests.
Non-Recourse Deductions and Tax Loss from a transaction not constituting a dissolution of the Partnership as defined in Article 9.3(d)(i) shall be allocated 100% to the Series 100 Limited Partners until such Limited Partners have received Distributions of any type in an amount equal to their total cash Capital Contributions plus the aggregate Preferred Return, if and when such Preferred Return is payable; next, 100% to the Series EA Limited Partners until such Limited Partners have received Distributions of any type in an amount equal to 25% of the amount distributed pursuant to the preceding clause, excluding any Distribution of the Preferred Return; next, 100% to the Series 200 Limited Partners until such Limited Partners have received Distributions of any type in an amount equal to their total cash Capital Contributions; next, 100% to the Series 300 Limited Partners until such Limited Partners have received Distributions of any type in an amount equal to their total cash Capital Contributions; next, 100% to the Datalinc Limited Partner until such Limited Partner has received Distributions of any type in an amount equal to the following amount: the aggregate total cash Capital Contributions of Series 100, Series 200 Series 300 Limited Partners divided by the aggregate percentage interests of the Limited Partners in the Final Clause multiplied by 73.052%, subject to increase with any unpurchased Series 300 Units or Managing Dealer Units percentage interest reallocated to all Limited Partners, or the Datalinc Limited Partner, respectively, as specified below, and subject to decrease by any amount distributed pursuant to the Series 100 Preferred Return and Section 9.4 or to the ILC Limited Partner; next, 100% to the Managing Dealer Limited Partner until such Limited Partner has received Distributions of any type in an amount equal to the following amount: the aggregate total cash Capital Contributions of Series 100, EA, 200, and 300 Limited Partners divided by the aggregate percentage interests of the Series 100, EA, 200, and 300 Limited Partners in the Final Clause multiplied by 2.171%, or such lesser percentage as is actually owned by the Managing Dealer Limited Partners; next, 100% to the General Partner until such General Partner has received Distributions of any type in an amount equal to the following amount: the aggregate total cash Capital Contributions of Series 100, EA, 200, and 300 Limited Partners divided by the aggregate percentage interests of the Series 100, EA, 200...
