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).
Appears in 10 contracts
Samples: Business Combination Agreement (FinTech Acquisition Corp. IV), Agreement (Perella Weinberg Partners), Business Combination Agreement (dMY Technology Group, Inc.)
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Holders of Partnership Common Units in accordance with their respective Percentage InterestsPartnership Common Units. 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 Section 1.704-2(i).
Appears in 8 contracts
Samples: Agreement (Aimco OP L.P.), Aimco OP L.P., Apartment Income REIT Corp.
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 Percentage InterestsPartnership Units. 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 Section 1.704-2(i).
Appears in 6 contracts
Samples: Agreement (Pacific Office Properties Trust, Inc.), Agreement (Pacific Office Properties Trust, Inc.), Agreement (Arizona Land Income Corp)
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Fiscal Year fiscal year shall be specially allocated to the Holders Partners in accordance with their respective Percentage InterestsInterest in Common Units. Any Partner Nonrecourse Deductions for any Fiscal Year fiscal year shall be specially allocated to the Holder(sPartner(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 Sections 1.704-2(b)(4) and 1.704-2(i).
Appears in 5 contracts
Samples: Assignment and Assumption Agreement (Amb Property Corp), Assignment and Assumption Agreement (Amb Property Lp), Assignment and Assumption Agreement (Amb Property Corp)
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Fiscal Year fiscal year shall be specially allocated to the Holders in accordance with their respective Percentage InterestsInterest in Common Units. Any Partner Nonrecourse Deductions for any Fiscal Year 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 Sections 1.704-2(b)(4) and 1.704-2(i).
Appears in 5 contracts
Samples: Kilroy Realty, L.P., Kilroy Realty, L.P., Kilroy Realty Corp
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 Section 1.704-2(i).
Appears in 4 contracts
Samples: Blue Owl Capital Inc., Blue Owl Capital Inc., Blue Owl Capital Inc.
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Fiscal Year fiscal year shall be specially allocated to the Holders in accordance with their respective Percentage InterestsInterest in Class A Common Units. Any Partner Nonrecourse Deductions for any Fiscal Year 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 Sections 1.704-2(b)(4) and 1.704-2(i).
Appears in 2 contracts
Samples: Ii Contribution Agreement (Amb Property Corp), Ii Contribution Agreement (Amb Property Lp)
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 InterestsGeneral Partner. Any Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Holder(sUnitholder(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 Section 1.704-2(i).
Appears in 1 contract
Samples: Agreement (Koger Equity Inc)