Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Partnership Year shall be specially allocated to the Holders in accordance with their respective Percentage Interests. 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).
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Holders in accordance with their respective Percentage Interests. Any Partner Nonrecourse Deductions for any Fiscal 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).
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Partnership Year shall be specially allocated to the Holders of OP Units in accordance with their OP Units. 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).
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any fiscal year shall be specially allocated to the Partners in accordance with their Percentage Interests. Any Partner Nonrecourse Deductions for any fiscal year shall be specially allocated to the Partner(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 Sections 1.704-2(b)(4) and 1.704-2(i).
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any --------------------------------------------------------- Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Holders of Partnership Units in accordance with their respective shares of the Nonrecourse Liabilities of the Partnership, determined in accordance with Section 1.752-3 of the Treasury Regulations. Any Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Unitholder(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 Section 1.7042(i) of the Treasury Regulations.
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Partnership taxable year generally shall be allocated to the Partners in accordance with their Partnership Interests; provided, however, that the General Partner may allocate Nonrecourse Deductions in a different manner so long as such allocation is reasonably consistent with allocations of some other significant Partnership item attributable to the Property securing the relevant Nonrecourse Liability that have substantial economic effect in accordance with Regulations Section 1.702-2(e)(2). Any Partner Nonrecourse Deductions for any Partnership taxable year shall be specially allocated to the Partner(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 Sections 1.704-2(b)(4) and 1.704-2(i).
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Company Year shall be specially allocated to the Holders of Units in accordance with their Capital Accounts. Any Partner Nonrecourse Deductions for any Company 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).
Nonrecourse Deductions and Partner Nonrecourse Deductions. (i) Nonrecourse Deductions shall be allocated to the Partners and/or Unit Holders in accordance with their Sharing Ratios. For purposes of this Section 3.3(f), “Sharing Ratios” means 21% to the Managing General Partner and 79% to the Investor Partners in proportion to the number of outstanding Units held by each.
Nonrecourse Deductions and Partner Nonrecourse Deductions. Nonrecourse deductions (as defined in Temp. Treas. Reg. §1.704-1T(b)(4)(iv)(a)(1)) shall be allocated in accordance with the Percentage Interests of the Partners, and partner nonrecourse deductions (as defined in Temp. Treas. Reg. §1.704-1T(b)(4)(iv)(h)(2)) shall be allocated, pursuant to Temp. Treas. Reg. §1.704-1T(b)(4)(iv)(h)(2), to the Partner who bears the economic risk of loss for the debt to which such partner nonrecourse deductions are attributable.
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions related to Baymeadows (as determined by the General Partner) for any Fiscal Year shall be allocated 98% to the General Partner and 2% to the holders of Class A Partnership Units (pro rata to the number of Class A Units held by them) and any Nonrecourse Deductions related to Westchase (as determined by the General Partner) for any Fiscal Year shall be allocated to the General Partner and to the holders of the Class A Partnership Units, based on their respective Westchase Contribution Percentages. Any Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Unitholder(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).
