Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations).
Appears in 113 contracts
Sources: Limited Partnership Agreement (HappyNest REIT, Inc.), Limited Partnership Agreement (HappyNest REIT, Inc.), Limited Partnership Agreement (Sila Realty Trust, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt Fiscal Year shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Deductions are attributable in accordance with Regulations Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i).
Appears in 36 contracts
Sources: Agreement of Limited Partnership (FrontView REIT, Inc.), Agreement of Limited Partnership (FrontView REIT, Inc.), Limited Partnership Agreement (Freehold Properties, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that Member who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Section 1.704-2(i)(1) of the Treasury Regulations).
Appears in 21 contracts
Sources: Operating Agreement, Operating Agreement (South Dakota Soybean Processors LLC), Operating Agreement (South Dakota Soybean Processors LLC)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Treasury Regulation section 1.704-2(i)(1) of the Regulations).
Appears in 18 contracts
Sources: Parent Agreement (BGC Partners, Inc.), Partnership Agreement (BGC Partners, Inc.), Parent Agreement (Newmark Group, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions nonrecourse deductions (as defined in Regulation §1.704-2(i)(1) and §1.704-2(i)(2)) for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt Year shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner nonrecourse debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and nonrecourse deductions are attributable in accordance with Regulation §1.704-2(i)(1) of the Regulations).
Appears in 16 contracts
Sources: Limited Partnership Agreement (MPT of West Anaheim, LLC), Limited Partnership Agreement (MPT of West Anaheim, LLC), Limited Partnership Agreement (MPT of West Anaheim, LLC)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year Fiscal Year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for the debt (i.e., the partner nonrecourse debt) in respect of which such Partner Nonrecourse Debt Deductions are attributable (as determined under Regulation Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations(i)(1)).
Appears in 15 contracts
Sources: Limited Partnership Agreement (CBL/Regency I, LLC), Limited Partnership Agreement (CBL/Regency I, LLC), Limited Partnership Agreement (CBL/Regency I, LLC)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for the debt (i.e., the Partner Nonrecourse Debt) in respect of which such Partner Nonrecourse Debt Deductions are attributable (as determined under Sections Regulation Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations(i)(1)).
Appears in 15 contracts
Sources: Agreement of Limited Partnership (Brookfield Property REIT Inc.), Limited Partnership Agreement (Brookfield Property REIT Inc.), Merger Agreement (Brookfield Property Partners L.P.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt Fiscal Year shall be specially allocated to the Partner that Owner who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with section 1.704-2(i)(1) of the Regulations).
Appears in 14 contracts
Sources: Trust Agreement, Trust Agreement (National Collegiate Student Loan Trust 2006-3), Trust Agreement (National Collegiate Student Loan Trust 2007-1)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations).
Appears in 14 contracts
Sources: Limited Partnership Agreement (American Finance Trust, Inc), Limited Partnership Agreement (Global Net Lease, Inc.), Limited Partnership Agreement (American Realty Capital Trust V, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt Allocation Year shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1) of the Regulations).
Appears in 13 contracts
Sources: Partnership Agreement (Wcof, LLC), Limited Partnership Agreement (Howard Midstream Partners, LP), Limited Partnership Agreement (Howard Midstream Partners, LP)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall Fiscal Year will be specially allocated to the Partner that who bears the economic risk of loss for such with respect to the Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and to which the Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i)(1) of the Regulations).
Appears in 12 contracts
Sources: Contribution Agreement, Agreement of Limited Partnership (Dominion Midstream Partners, LP), Agreement of Limited Partnership (Columbia Pipeline Partners LP)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt Fiscal Year shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Deductions are attributable in accordance with Treasury Regulations Sections 1.704-2(b)(42(i)(1) and 1.704-2(i)(1) of the Regulations2(j)(1).
Appears in 12 contracts
Sources: Limited Partnership Agreement (Rocket Companies, Inc.), Limited Partnership Agreement (Galaxy Digital Inc.), Limited Partnership Agreement (Galaxy Digital Holdings Ltd.)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year or other applicable period Fiscal Year with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner Partners that bears bear the economic risk of loss for such Partner Nonrecourse Debt (as determined under Treasury Regulations Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations).
Appears in 12 contracts
Sources: Limited Partnership Agreement (Healthcare Realty Holdings, L.P.), Merger Agreement (Healthcare Realty Trust Inc), Limited Partnership Agreement (American Healthcare REIT, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially specifically allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i).
Appears in 12 contracts
Sources: Limited Partnership Agreement, Limited Partnership Agreement (UHS of Timberlawn, Inc.), Limited Partnership Agreement (UHS of Timberlawn, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable, in accordance with Regulations Section 1.704-2(i)(1) of the Regulations).
Appears in 8 contracts
Sources: Limited Partnership Agreement (Erp Operating LTD Partnership), Limited Partnership Agreement (Acadia Realty Trust), Limited Partnership Agreement (Equity Residential)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions nonrecourse deductions (as described in Section 1.704-2(i) of the Treasury Regulations) for any fiscal year Fiscal Year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially specifically allocated to the Partner that bears Members who bear the economic risk of loss for such with respect to Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and to which such partner nonrecourse deductions are attributable in accordance with Section 1.704-2(i)(1) of the Treasury Regulations).
Appears in 7 contracts
Sources: Limited Liability Company Operating Agreement (National CineMedia, Inc.), Limited Liability Company Operating Agreement (National CineMedia, Inc.), Limited Liability Company Operating Agreement (National CineMedia, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Treas. Reg. Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i).
Appears in 7 contracts
Sources: Limited Partnership Agreement (PDC 2003-C Lp), Limited Partnership Agreement (Rockies Region 2007 Lp), Limited Partnership Agreement (Rockies Region 2007 Lp)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year or other applicable period Fiscal Year with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner Partners that bears bear the economic risk of loss for such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the Treasury Regulations).
Appears in 7 contracts
Sources: Limited Partnership Agreement (Paladin Realty Income Properties Inc), Agreement of Limited Partnership (Paladin Realty Income Properties Inc), Agreement of Limited Partnership (Paladin Realty Income Properties Inc)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Section 1.704-2(b)(4) and 1.704-2(i)(12(i) of the Treasury Regulations).
Appears in 7 contracts
Sources: Limited Partnership Agreement (Duke Realty Limited Partnership/), Limited Partnership Agreement (Duke Realty Limited Partnership/), Limited Partnership Agreement (Duke Realty Limited Partnership/)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations)Deductions are attributable.
Appears in 7 contracts
Sources: Limited Partnership Agreement (Cke Restaurants Inc), Limited Partnership Agreement (Aeroways, LLC), Limited Partnership Agreement (Verso Paper Corp.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt Fiscal Year shall be specially allocated to the Partner that Member who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with section 1.704-2(i)(1) of the Regulations).
Appears in 6 contracts
Sources: Limited Liability Company Agreement (Figure Technology Solutions, Inc.), Limited Liability Company Agreement (FT Intermediate, Inc.), Limited Liability Company Agreement (FT Intermediate, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year Fiscal Year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears (or is deemed to bear) the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Regulations Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i)(2).
Appears in 6 contracts
Sources: Partnership Agreement, Partnership Agreement (Dividend Capital Total Realty Trust Inc.), Partnership Agreement (Dividend Capital Total Realty Trust Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Deductions are attributable in accordance with Regulations Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i).
Appears in 6 contracts
Sources: Limited Partnership Agreement (Crescent Real Estate Equities Co), Limited Partnership Agreement (Crescent Real Estate Equities Co), Limited Partnership Agreement (Crescent Real Estate Equities Co)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Treas. Reg. § 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i).
Appears in 6 contracts
Sources: Limited Partnership Agreement (PDC 2002 B LTD Partnership), Limited Partnership Agreement (PDC 2002 C LTD Partnership), Limited Partnership Agreement (PDC 2003-a Lp)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions ------------------------------ for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for the debt (i.e., the Partner Nonrecourse Debt) in respect of which such Partner Nonrecourse Debt Deductions are attributable (as determined under Sections Regulation Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations(i)(1)).
Appears in 5 contracts
Sources: Fifth Amendment to the First Amended and Restated Agreement of Limited Partnership (Essex Property Trust Inc), Fourth Amendment to the First Amended and Restated Agreement of Limited Partnership (Essex Portfolio Lp), Fifth Amendment to First Amended and Restated Agreement of Limited Partnership (Essex Portfolio Lp)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt Allocation Period shall be specially allocated to the Partner that bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1) of the Regulations).
Appears in 5 contracts
Sources: Limited Partnership Agreement (Wealthcasa Capital Fund, LP), Limited Partnership Agreement (UC Asset LP), Limited Partnership Agreement (UC Asset LP)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner Member that bears the economic risk of loss for the debt (i.e., the Partner Nonrecourse Debt) to which such Partner Nonrecourse Debt Deductions are attributable (as determined under Sections Regulation Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations(i)(1)).
Appears in 5 contracts
Sources: Operating Agreement (General Growth Properties, Inc.), Operating Agreement (New GGP, Inc.), Operating Agreement (New GGP, Inc.)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year Fiscal Year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for the debt (i.e., the partner nonrecourse debt) in respect of which such Partner Nonrecourse Debt Deductions are attributable (as determined under Regulation Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations(i)(l)).
Appears in 5 contracts
Sources: Limited Partnership Agreement (CBL/Regency I, LLC), Limited Partnership Agreement (CBL/Regency I, LLC), Limited Partnership Agreement (CBL/Regency I, LLC)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt Fiscal Year shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i)(1) of the Regulations).
Appears in 5 contracts
Sources: Agreement of Limited Partnership (Triangle Capital CORP), Agreement of Limited Partnership (Triangle Mezzanine Fund LLLP), Limited Partnership Agreement (Triangle Capital CORP)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations)Debt.
Appears in 5 contracts
Sources: Limited Partnership Agreement (National Healthcare Properties, Inc.), Agreement of Limited Partnership (Healthcare Trust, Inc.), Agreement of Limited Partnership (Healthcare Trust, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse ------------------------------ Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Regulations Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i)(2).
Appears in 5 contracts
Sources: Limited Partnership Agreement (Cabot Industrial Properties Lp), Limited Partnership Agreement (Cabot Industrial Trust), Contribution Agreement (Cabot Industrial Trust)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt Deductions are attributable in accordance with Regulations (as determined under Sections 1.704-2(b)(4S) and 1.704-2(i)(1) of the Regulations).
Appears in 4 contracts
Sources: Partnership Agreement (Infoseek Corp /De/), Partnership Agreement (Walt Disney Co/), Partnership Agreement (Walt Disney Co/)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions Any partner nonrecourse deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the partner nonrecourse debt to which such Partner Nonrecourse Debt (as determined under Sections partner nonrecourse deductions are attributable in accordance with Regulation §1.704-2(b)(42(i) and or §1.704-2(i)(1) of the Regulations2(k).
Appears in 4 contracts
Sources: Limited Partnership Agreement (Millennium Chemicals Inc), Limited Partnership Agreement (Millennium Chemicals Inc), Limited Partnership Agreement (Equistar Chemicals Lp)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year Fiscal Year or other applicable relevant period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Deductions are attributable in accordance with Regulations Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i).
Appears in 4 contracts
Sources: Agreement of Limited Partnership (InfraREIT, Inc.), Limited Partnership Agreement (InfraREIT, Inc.), Limited Partnership Agreement (InfraREIT, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that or Interest Holder who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1) of the Regulations).
Appears in 4 contracts
Sources: Limited Partnership Agreement (OCI Resources LP), Limited Partnership Agreement (OCI Resources LP), Agreement of Limited Partnership (OHI Asset (CT) Lender, LLC)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year year, quarter or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations).
Appears in 4 contracts
Sources: Limited Partnership Agreement (American Realty Capital Global Trust II, Inc.), Limited Partnership Agreement (American Realty Capital Healthcare Trust III, Inc.), Limited Partnership Agreement (American Realty Capital New York City REIT II, Inc.)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any ------------------------------ fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for the debt in respect of which such Partner Nonrecourse Debt Deductions are attributable (as determined under Regulations Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations(i)(1)).
Appears in 4 contracts
Sources: Second Amended and Restated Agreement of Limited Partnership (Weeks Corp), Second Amended and Restated Agreement of Limited Partnership (Weeks Realty L P), Second Amended and Restated Agreement of Limited Partnership (Weeks Realty L P)
Partner Nonrecourse Deductions. Partner Nonrecourse ------------------------------ Deductions for any fiscal year Partnership Fiscal Year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1) of the Regulations).
Appears in 4 contracts
Sources: Limited Partnership Agreement (Petro Holdings Financial Corp), Limited Partnership Agreement (Petro Stopping Centers L P), Limited Partnership Agreement (Petro Stopping Centers L P)
Partner Nonrecourse Deductions. In accordance with Regulations Section 1.704-2(i)(l), any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt Fiscal Year shall be specially specifically allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations)Deductions are attributable.
Appears in 4 contracts
Sources: General Partnership Agreement (UHS of Timberlawn, Inc.), General Partnership Agreement (UHS of Timberlawn, Inc.), General Partnership Agreement (BHC Meadows Partner Inc)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year Partnership Year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations).
Appears in 4 contracts
Sources: Limited Partnership Agreement (Phillips Edison & Company, Inc.), Contribution Agreement (Phillips Edison Grocery Center Reit I, Inc.), Contribution Agreement (Phillips Edison Grocery Center Reit I, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions (as described in Article XVI hereof) for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that Member who bears the economic risk of loss for such with respect to the Partner Nonrecourse Debt (as determined under Sections described in Article XVI hereof) to which such Partner Nonrecourse Deductions are attributable in accordance with Section 1.704-2(b)(4) and 1.704-2(i)(12(i)(2) of the Regulations).
Appears in 3 contracts
Sources: Operating Agreement (Liquidmetal Technologies Inc), Securities Purchase Agreement (Liquidmetal Technologies Inc), Asset Purchase and Contribution Agreement (Liquidmetal Technologies Inc)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Regulations Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i)(2).
Appears in 3 contracts
Sources: Limited Partnership Agreement (Carramerica Realty Corp), Limited Partnership Agreement (Carramerica Realty Corp), Limited Partnership Agreement (Baron Capital Trust)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that Member who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Deductions are attributable in accordance with Regulations Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i)(2).
Appears in 3 contracts
Sources: Master Purchase Agreement (Morgans Hotel Group Co.), Limited Liability Company Agreement (Morgans Hotel Group Co.), Limited Liability Company Agreement (Morgans Hotel Group Co.)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions nonrecourse deductions (as described in Treasury Regulation Section 1.704-2(i)) for any fiscal year Fiscal Year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially specifically allocated to the Partner that bears Members who bear the economic risk of loss for such with respect to Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and to which such partner nonrecourse deductions are attributable in accordance with Treasury Regulation Section 1.704-2(i)(1) of the Regulations).
Appears in 3 contracts
Sources: Limited Liability Company Agreement (Cloud Peak Energy Inc.), Limited Liability Company Agreement (Cloud Peak Energy Inc.), Limited Liability Company Agreement (Cloud Peak Energy Inc.)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and 1.704-2(i)(12(i)(l) of the Regulations).
Appears in 3 contracts
Sources: Limited Partnership Agreement (Carlyle Real Estate LTD Partnership Xiii), Limited Partnership Agreement (Carlyle Real Estate LTD Partnership Xiv /Il/), Limited Partnership Agreement (JMB Manhattan Associates LTD)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall will be specially allocated to the Partner that Member who bears the economic risk of loss for such with respect to the Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and to which the Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section 1.704-2(i)(1) of the Regulations).
Appears in 3 contracts
Sources: Operating Agreement (Rex Energy Corp), Operating Agreement (Rex Energy Corp), Limited Liability Company Agreement (Rex Energy Corp)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions Any partner nonrecourse deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the loan to which such Partner Nonrecourse Debt (as determined under Sections partner nonrecourse deduction is attributable in accordance with Regulations Section 1.704-2(b)(4) and 2(i), if such sections of the Regulations become applicable to the Partnership. Partner nonrecourse debt minimum gain shall be charged back to the Partners in accordance with Regulations Section 1.704-2(i)(1) of the Regulations2(i)(4).
Appears in 3 contracts
Sources: Agreement of Limited Partnership (Frost Phillip Md Et Al), Limited Partnership Agreement (Frost Phillip Md Et Al), Limited Partnership Agreement (Frost Phillip Md Et Al)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions Any partner nonrecourse deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that Member who bears the economic risk of loss for with respect to the partner nonrecourse debt to which such Partner Nonrecourse Debt (as determined under Sections partner nonrecourse deductions are attributable in accordance with Regulations § 1.704-2(b)(42(i) and or 1.704-2(i)(1) of the Regulations2(k).
Appears in 3 contracts
Sources: Limited Liability Company Agreement (American Casino & Entertainment Properties LLC), Limited Liability Company Agreement (Colony Resorts LVH Acquisitions LLC), Limited Liability Company Agreement (Colony Resorts LVH Acquisitions LLC)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year Fiscal Year (or any other applicable period with respect in which it is necessary to a Partner Nonrecourse Debt make allocations of Net Income or Net Losses) shall be specially allocated to the Partner that who bears the economic risk of loss for losses with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i)(1) of the Regulations).
Appears in 3 contracts
Sources: Limited Partnership Agreement (Essex Property Trust Inc), Fifteenth Amendment to First Amended and Restated Agreement of Limited Partnership (Essex Property Trust Inc), Agreement of Limited Partnership (Essex Portfolio Lp)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal taxable year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for the debt (i.e., the Partner Nonrecourse Debt) in respect of which such Partner Nonrecourse Debt Deductions are attributable (as determined under Sections 1.704-2(b)(4) and 1.704-2(i)(1(i)(1) of the Regulations).
Appears in 3 contracts
Sources: Limited Partnership Agreement (Prime Retail Inc), Limited Partnership Agreement (Sky Merger Corp), Limited Partnership Agreement (Sky Merger Corp)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year Fiscal Year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially especially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1) of the Regulations).
Appears in 3 contracts
Sources: Limited Partnership Agreement (Capital Lodging), Limited Partnership Agreement (Capital Lodging), Limited Partnership Agreement (First Potomac Realty Trust)
Partner Nonrecourse Deductions. Notwithstanding Section 4.1, any Partner Nonrecourse Deductions nonrecourse deductions (as defined in Regulation § 1.704-2(i)(1)) for any fiscal taxable year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially specifically allocated to the Partner that who bears the economic risk of loss for with respect to the Partner nonrecourse debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and deductions are attributable in accordance with Regulation § 1.704-2(i)(1) of the Regulations).
Appears in 3 contracts
Sources: Limited Partnership Agreement (Sabine Pass LNG, L.P.), Limited Partnership Agreement (Cheniere Energy Inc), Limited Partnership Agreement (Sabine Pass LNG, L.P.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse ------------------------------ Deductions for any fiscal year Fiscal Year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i).
Appears in 3 contracts
Sources: Limited Partnership Agreement (Insight Capital Inc), Limited Partnership Agreement (Insight Capital Inc), Limited Partnership Agreement (Insight Communications Co Inc)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for the debt (i.e., the Partner Nonrecourse Debt) in respect of which such Partner Nonrecourse Debt Deductions are attributable (as determined under Sections Regulation Section 1.704-2(b)(42(b) (4) and 1.704-2(i)(1(i) of the Regulations(1)).
Appears in 3 contracts
Sources: Limited Partnership Agreement (Trump Plaza Associates), Agreement of Limited Partnership (Trump Entertainment Resorts Holdings Lp), Limited Partnership Agreement (Trump Donald J)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions Any partner nonrecourse deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that Member who bears the economic risk of loss for with respect to the partner nonrecourse debt to which such Partner Nonrecourse Debt (as determined under Sections partner nonrecourse deductions are attributable in accordance with Treasury Regulations ss. 1.704-2(b)(42(i) and or 1.704-2(i)(1) of the Regulations2(k).
Appears in 3 contracts
Sources: Agreement and Plan of Merger (Mecklermedia Corp), Agreement and Plan of Merger (Penton Media Inc), Agreement and Plan of Merger (Penton Media Inc)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for the debt in respect of which such Partner Nonrecourse Debt Deductions are attributable (as determined under Sections Section 1.704-2(b)(4) and 1.704-2(i)(1(i)(1) of the Regulations).
Appears in 3 contracts
Sources: Joint Venture Agreement (NGA Holdco, LLC), Limited Partnership Agreement (Advanta Corp), Investment Agreement (Shreveport Capital Corp)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year Fiscal Year (or any other applicable period with respect in which it is necessary to a Partner Nonrecourse Debt make allocations of Profit or Loss) shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1) of the Regulations).
Appears in 2 contracts
Sources: Limited Partnership Agreement, Limited Partnership Agreement
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Section 1.704-2(b)(4) and 1.704-2(i)(12(i) of the Regulations).
Appears in 2 contracts
Sources: Limited Partnership Agreement, Limited Partnership Agreement
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt Fiscal Year shall be specially allocated to the Partner that bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with section 1.704-2(b)(4) and 1.704-2(i)(12(i)(2) of the Regulations).
Appears in 2 contracts
Sources: Limited Partnership Agreement (LXP Industrial Trust), Limited Partnership Agreement (Lepercq Corporate Income Fund L P)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner Partner(s) that bears bear(s) the economic risk of loss for the debt in respect of which such Partner Nonrecourse Debt Deductions are attributable (as determined under Sections Section 1.704-2(b)(4) and 1.704-2(i)(1(i)(1) of the Regulations).
Appears in 2 contracts
Sources: Limited Partnership Agreement (Silvercrest Asset Management Group Inc.), Limited Partnership Agreement (Silvercrest Asset Management Group Inc.)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for the debt (i.e., the partner nonrecourse debt) in respect of which such Partner Nonrecourse Debt Deductions are attributable (as determined under Sections Regulation Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations(i)(l)).
Appears in 2 contracts
Sources: Limited Partnership Agreement (HTS-Sunset Harbor Partner, L.L.C.), Partnership Agreement (HTS-Sunset Harbor Partner, L.L.C.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year Fiscal Year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Treasury Regulation Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i).
Appears in 2 contracts
Sources: Partnership Agreement (Adelphia Communications Corp), Limited Partnership Agreement (Paxson Minneapolis License Inc)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year Fiscal Year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i)(1) of the Regulations).
Appears in 2 contracts
Sources: Purchase Agreement (Cedar Shopping Centers Inc), Purchase Agreement (Cedar Shopping Centers Inc)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year Fiscal Year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Section 1.704-2(i)(1) of the Regulations).
Appears in 2 contracts
Sources: Limited Partnership Agreement (Tejas Gas Corp), Limited Partnership Agreement (Tejas Gas Corp)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt Fiscal Year shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Regulations section 1.704-2(i)(1) of the Regulations).
Appears in 2 contracts
Sources: Limited Partnership Agreement (Ashford Hospitality Trust Inc), Limited Partnership Agreement (Ashford Hospitality Trust Inc)
Partner Nonrecourse Deductions. Any Partner Loan Nonrecourse Deductions for any Partnership fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the loan to which such Partner Loan Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Regulations Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i)(2).
Appears in 2 contracts
Sources: Limited Partnership Agreement (Inergy Storage, Inc.), Limited Partnership Agreement (Inergy Storage, Inc.)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year Partnership Fiscal Year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1) of the Regulations).
Appears in 2 contracts
Sources: Limited Partnership Agreement (Petro, Inc.), Limited Partnership Agreement (Petro, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Treasury Regulation Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i).
Appears in 2 contracts
Sources: Limited Partnership Agreement (National Patent Development Corp), Limited Partnership Agreement (National Patent Development Corp)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions Any partner nonrecourse deductions ------------------------------ for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the partner nonrecourse debt to which such Partner Nonrecourse Debt (as determined under Sections partner nonrecourse deductions are attributable in accordance with Regulation Section 1.704-2(b)(42(i) and or Section 1.704-2(i)(1) of the Regulations2(k).
Appears in 2 contracts
Sources: Limited Partnership Agreement (Equistar Chemicals Lp), Limited Partnership Agreement (Lyondell Chemical Co)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially specifically allocated to the Partner that bears Partner(s) who bear(s) the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Regulations Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i).
Appears in 2 contracts
Sources: Limited Partnership Agreement (Agree Realty Corp), Limited Partnership Agreement (Agree Realty Corp)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for the debt (i.e., the partner nonrecourse debt) in respect of which such Partner Nonrecourse Debt Deductions are attributable (as determined under Sections Regulation Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations(i)(1).
Appears in 2 contracts
Sources: Limited Partnership Agreement (HTS-Sunset Harbor Partner, L.L.C.), Limited Partnership Agreement (HTS-Sunset Harbor Partner, L.L.C.)
Partner Nonrecourse Deductions. Notwithstanding any other provisions of this Agreement, any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that Member who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Section 1.704-2(b)(4) and 1.704-2(i)(12(i) of the Regulations).;
Appears in 2 contracts
Sources: Limited Liability Company Agreement, Limited Liability Company Agreement
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt Fiscal Year shall be specially allocated to the Partner that bears the economic risk of loss for with respect to the liability to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Treasury Regulations § 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(j).
Appears in 2 contracts
Sources: Limited Partnership Agreement, Limited Partnership Agreement
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt Fiscal Period shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations)2.
Appears in 2 contracts
Sources: Limited Partnership Agreement (Kiewit Investment Fund LLLP), Limited Partnership Agreement (Kiewit Investment Fund LLLP)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions ------------------------------ for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt Partnership Year shall be specially specifically allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Regulations Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i).
Appears in 2 contracts
Sources: Agreement of Limited Partnership (Cavanaughs Hospitality Corp), Agreement of Limited Partnership (Cavanaughs Hospitality Corp)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Regulations Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i).
Appears in 2 contracts
Sources: Limited Partnership Agreement (New Gaming Capital Partnership), Limited Partnership Agreement (Lexreit Properties Inc)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall will be specially allocated each Allocation Period to the Partner that bears the economic risk of loss (within the meaning of Treasury Regulations Section 1.752-2) for the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations)Deductions are attributable.
Appears in 2 contracts
Sources: Agreement of Limited Partnership (Rice Energy Inc.), Agreement of Limited Partnership (Southcross Energy LLC)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year Fiscal Year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Regulations Section 1.704-2(b)(42(i) and 1.704-2(i)(1) of the Regulations2(k).
Appears in 2 contracts
Sources: Limited Partnership Agreement (Argosy of Iowa Inc), Limited Partnership Agreement (Argosy of Iowa Inc)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year Fiscal Year of the Company or other applicable period with respect to a Partner Nonrecourse Debt portion thereof shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the nonrecourse debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable, in accordance with Treasury Regulations Section 1.704-2(i)(1) of the Regulations).
Appears in 2 contracts
Sources: Limited Partnership Agreement (Cedar Shopping Centers Inc), Limited Partnership Agreement (Cedar Shopping Centers Inc)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1) of the Regulations).
Appears in 2 contracts
Sources: Limited Partnership Agreement (Foundation Capital Resources Inc), Agreement of Limited Partnership (Foundation Capital Resources Inc)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable shorter period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that holder of Financial Rights who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Regulations section 1.704-2(i)(1) of the Regulations).
Appears in 2 contracts
Sources: Operating Agreement (Dynamic Associates Inc), Operating Agreement (Dynamic Associates Inc)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt Fiscal Year shall be specially allocated to the Partner that who bears the economic risk of loss for loss, under Regulations Section 1.704-2(i)(1), with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Regulations Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i)(2).
Appears in 2 contracts
Sources: Partnership Agreement (Macerich Co), Partnership Agreement (Simon Debartolo Group Inc)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions ------------------------------- for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt Partnership Year shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Deductions are attributable in accordance with Regulations Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i).
Appears in 2 contracts
Sources: Agreement of Limited Partnership (Host Marriott Trust), Agreement of Limited Partnership (Host Marriott L P)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for the debt (i.e., the partner nonrecourse debt) in respect of which such Partner Nonrecourse Debt Deductions are attributable (as determined under Sections Regulation Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations(i)(1)).
Appears in 1 contract
Sources: Limited Partnership Agreement (HTS-Sunset Harbor Partner, L.L.C.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year Fiscal Year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Regulations Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations1T(b)(4)(iv)(h).
Appears in 1 contract
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that Member who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Deductions are attributable in accordance with Regulations Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i)(2).. Third Amended and Restated Limited Liability Company Agreement | 16
Appears in 1 contract
Sources: Equity Purchase Agreement (Morgans Hotel Group Co.)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions ------------------------------ for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for the debt in respect of which such Partner Nonrecourse Debt Deductions are attributable (as determined under Sections Section 1.704-2(b)(4) and 1.704-2(i)(1(i)(1) of the Regulations).
Appears in 1 contract
Sources: Limited Partnership Agreement (RMH Teleservices Inc)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for ------------------------------ any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for such Partner Nonrecourse Debt (as determined under Sections 1.704-1.704- 2(b)(4) and 1.704-2(i)(1) of the Regulations).
Appears in 1 contract
Sources: Limited Partnership Agreement (Meristar Hospitality Corp)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt Fiscal Year shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1) of the Regulations).
Appears in 1 contract
Sources: Operating Agreement
Partner Nonrecourse Deductions. Any Partner Nonrecourse ------------------------------ Deductions for any fiscal year Fiscal Year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations).Deductions are attributable in accordance with Regulations Section 1.704-
Appears in 1 contract
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year or other applicable allocation period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i)(1) of the Regulations).
Appears in 1 contract
Partner Nonrecourse Deductions. In accordance with Regulations Section 1.704-2(i)(1), any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt Fiscal Year shall be specially specifically allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations)Deductions are attributable.
Appears in 1 contract
Sources: General Partnership Agreement (Psychiatric Solutions Inc)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Treasury Regulations section 1.704-2(i)(1) of the Regulations).
Appears in 1 contract
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and to which those Partner Nonrecourse Deductions are attributable in accordance with Section 1.704-2(i)(1) of the Regulations).
Appears in 1 contract
Sources: Limited Partnership Agreement (New York City REIT, Inc.)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions Any "partner nonrecourse deductions" for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the "partner nonrecourse debt" to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and "partner nonrecourse deductions" are attributable in accordance with Section 1.704-2(i)(1) of the Regulations).
Appears in 1 contract
Sources: Limited Partnership Agreement (Manufactured Home Communities Inc)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Treasury Regulations section 1.704-2(i)(1) ). Table of the Regulations).Contents
Appears in 1 contract
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections Deductions are attributable in accordance with Treasury Regulation section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i)(2).
Appears in 1 contract
Sources: Limited Partnership Agreement (United Dominion Realty Trust Inc)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1) of the Regulations).
Appears in 1 contract
Sources: Limited Partnership Agreement (Atlantic Oklahoma Wind, LLC)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions Any partner nonrecourse deductions for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the partner nonrecourse debt to which such Partner Nonrecourse Debt (as determined under Sections partner nonrecourse deductions are attributable in accordance with Regulation §1.704-2(b)(42(1) and or §1.704-2(i)(1) of the Regulations2(k).. HOU03:1138115.4 11
Appears in 1 contract
Sources: Limited Partnership Agreement (LyondellBasell F&F Holdco, LLC)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions nonrecourse deductions (as defined in Regulation §1.704-2(i)(l) and §1.704-2(i)(2)) for any fiscal year or other applicable period with respect to a Partner Nonrecourse Debt Year shall be specially allocated to the Partner that who bears the economic risk of loss for with respect to the Partner nonrecourse debt to which such Partner Nonrecourse Debt (as determined under Sections 1.704-2(b)(4) and nonrecourse deductions are attributable in accordance with Regulation §1.704-2(i)(1) of the Regulations).
Appears in 1 contract
Sources: Limited Partnership Agreement (MPT of West Anaheim, LLC)