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).
Appears in 3 contracts
Samples: Subscription and Support Agreement (Blue Eagle Holdings, L.P.), Subscription and Support Agreement (Blue Eagle Holdings, L.P.), Contribution and Support Agreement (Innotrac Corp)
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 Members holding Common Units pro rata in accordance with their respective Preferred Common Units. The amount of non-recourse deductions and excess non-recourse liabilities shall be determined in accordance with Regulations Section 1.704-2(c).
Appears in 2 contracts
Samples: Securities Purchase Agreement (Nord Anglia Education, Inc.), Transaction Agreement (Nord Anglia Education, Inc.)
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 Members holding vested Common Units pro rata in accordance with their respective Preferred vested Common Units. The amount of non-recourse deductions and excess non-recourse liabilities shall be determined in accordance with Regulations Section 1.704-2(c).
Appears in 1 contract
Samples: Limited Liability Company Agreement
