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
Samples: Agreement (HappyNest REIT, Inc.), Form of Agreement (NY Residential REIT, LLC), Registration Rights Agreement (American Realty Capital Hospitality 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 34 contracts
Samples: Agreement (Broad Street Realty, Inc.), Agreement (Education Realty Operating Partnership L P), 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
Samples: 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
Samples: Parent Agreement (Newmark Group, Inc.), Parent Agreement (BGC Partners, Inc.), BGC Partners, 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
Samples: Agreement (MPT of West Anaheim, LLC), Agreement (MPT of West Anaheim, LLC), 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
Samples: Agreement (CBL/Regency I, LLC), Agreement (CBL/Regency I, LLC), 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
Samples: Agreement and Plan of Merger (Brookfield Property Partners L.P.), Agreement and Plan of Merger (Brookfield Asset Management Inc.), Agreement and Plan of Merger (GGP 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)(1) of the Regulations).
Appears in 14 contracts
Samples: Original Agreement (Global Net Lease, Inc.), Recitals (American Realty Capital Trust V, Inc.), Agreement (American Realty Capital Properties, 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 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
Samples: Trust Agreement, Trust Agreement (National Collegiate Student Loan Trust 2007-3), Trust Agreement (National Collegiate Funding LLC)
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
Samples: After (Wcof, LLC), Original Agreement (Howard Midstream Partners, LP), Original 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
Samples: Contribution Agreement, Agreement (Columbia Pipeline Partners LP), Agreement (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 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
Samples: www.sec.gov, Agreement of Limited Partnership (UHS of Timberlawn, Inc.), Agreement of Limited Partnership (UHS of Timberlawn, Inc.)
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
Samples: Agreement and Plan of Merger (Healthcare Realty Trust Inc), Healthcare Realty Holdings, L.P., 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 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 9 contracts
Samples: Limited Partnership Agreement (TPG Inc.), Limited Partnership Agreement (TPG Gp A, LLC), Limited Partnership Agreement (TPG 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
Samples: Limited Partnership Agreement (Acadia Realty Trust), Erp Operating LTD Partnership, Equity Residential
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
Samples: Limited Partnership Agreement (Cke Restaurants Inc), Limited Partnership Agreement (Aeroways, LLC), Limited Partnership Agreement (Verso Paper Holdings 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 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
Samples: Duke Realty Limited Partnership/, Duke Realty Limited Partnership/, Duke Realty Limited Partnership/
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
Samples: Limited Partnership Agreement (PDC 2003-C Lp), Limited Partnership Agreement (PDC 2004-B Limited Partnership), 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
Samples: Paladin Realty Income Properties Inc, Paladin Realty Income Properties Inc, 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 Treas. Reg. § 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i).
Appears in 6 contracts
Samples: 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. 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
Samples: 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
Samples: Crescent Real Estate Equities Co, Crescent Real Estate Equities Co, Agreement and Plan of Merger (Station Casinos 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
Samples: Agreement (Cabot Industrial Properties Lp), Contribution Agreement (Cabot Industrial Trust), Agreement (Cabot Industrial Properties 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
Samples: Limited Partnership Agreement (UC Asset LP), Limited Partnership Agreement (Wealthcasa Capital Fund, LP), Limited Partnership Agreement (UC Asset LP)
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
Samples: Agreement (CBL/Regency I, LLC), CBL/Regency I, LLC, 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 5 contracts
Samples: Essex Portfolio Lp, Essex Portfolio Lp, Essex Property 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 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
Samples: Agreement (Triangle Mezzanine Fund LLLP), Agreement (Triangle Capital CORP), 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 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
Samples: Operating Agreement (General Growth Properties, Inc.), Operating Agreement (New GGP, Inc.), Operating Agreement (New GGP, 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 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
Samples: Agreement (Equistar Chemicals Lp), Lease Agreement (Equistar Chemicals Lp), Agreement (Millennium Chemicals 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 4 contracts
Samples: Limited Partnership Agreement (Petro Stopping Centers L P), Limited Partnership Agreement (Petro Stopping Centers L P), Petro Stopping Centers L P
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
Samples: Agreement (American Realty Capital Healthcare Trust III, Inc.), Agreement (American Realty Capital New York City REIT II, Inc.), Form of 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
Samples: Weeks Corp, Weeks Realty L P, Weeks Corp
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
Samples: UHS of Timberlawn, Inc., UHS of Timberlawn, Inc., Agreement (BHC Meadows Partner Inc)
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
Samples: InfraREIT, Inc., InfraREIT, Inc., InfraREIT, 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
Samples: 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 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
Samples: Partnership Agreement (Walt Disney Co/), Partnership Agreement (Infoseek Corp /De/), Partnership Agreement (Infoseek Corp /De/)
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
Samples: OCI Resources LP, OCI Resources LP, OHI Asset (CT) Lender, 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 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 4 contracts
Samples: Healthcare Trust, Inc., Healthcare Trust, Inc., American Finance Trust, Inc
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 4 contracts
Samples: Limited Liability Company Operating Agreement (Amc Entertainment Inc), Limited Liability Company Operating Agreement (Marquee Holdings Inc.), Limited Liability Company Operating Agreement (National CineMedia, Inc.)
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
Samples: Essex Property Trust Inc, Essex Portfolio Lp, Essex Property Trust 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 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
Samples: Contribution and Formation Agreement (Insight Capital Inc), Insight Capital Inc, Insight Communications Co Inc
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
Samples: Crest Settlement Agreement (Sabine Pass LNG, L.P.), Limited Partnership Agreement (Cheniere Energy Inc), Settlement and Purchase Agreement (Sabine Pass LNG, 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 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
Samples: Limited Partnership Agreement (Advanta Corp), Joint Venture Agreement (NGA Holdco, LLC), Investment Agreement (Shreveport 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 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
Samples: Trump Plaza Associates, Trump Entertainment Resorts Holdings Lp, 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 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
Samples: Frost Phillip Md Et Al, Frost Phillip Md Et Al, Frost Phillip Md Et Al
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
Samples: Indemnification Agreement (Carlyle Real Estate LTD Partnership Xiv /Il/), Indemnification Agreement (JMB Manhattan Associates LTD), Indemnification Agreement (Carlyle Real Estate LTD Partnership Xiii)
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
Samples: Operating Agreement (Liquidmetal Technologies Inc), Operating 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 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
Samples: Limited Liability Company 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 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
Samples: 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. 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
Samples: Limited Liability Company Agreement (Rex Energy Corp), Operating Agreement (Rex Energy Corp), Operating Agreement (Rex Energy Corp)
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
Samples: 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. 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
Samples: Capital Lodging, Capital Lodging, First Potomac Realty Trust
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
Samples: Sky Merger Corp, Sky Merger Corp, Prime Retail 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
Samples: Carramerica Realty Corp, Carramerica Realty Corp, Baron Capital Trust
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
Samples: Limited Liability Company Agreement (Colony Resorts LVH Acquisitions LLC), Limited Liability Company Agreement (American Casino & Entertainment Properties LLC), Limited Liability Company Agreement (Colony Resorts LVH Acquisitions LLC)
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
Samples: Cavanaughs Hospitality Corp, Cavanaughs Hospitality 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 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
Samples: Adelphia Communications Corp, Partnership Agreement (Paxson Minneapolis License 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
Samples: 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 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
Samples: Registration Rights Agreement (Agree Realty Corp), Agree Realty 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 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
Samples: Lease Agreement (Cedar Shopping Centers Inc), Agreement Regarding Purchase of Partnership Interests (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 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
Samples: Original Agreement (Argosy of Iowa Inc), Argosy of Iowa 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
Samples: Registration Rights Agreement (Rice Energy Inc.), Agreement (Southcross Energy LLC)
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
Samples: 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 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
Samples: Limited Partnership Agreement (Kiewit Investment Fund LLLP), Limited Partnership Agreement (Kiewit Investment Fund LLLP)
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
Samples: Limited Partnership Agreement, Limited Partnership Agreement
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
Samples: Key Wester Limited (HTS-Sunset Harbor Partner, L.L.C.), Agreement (HTS-Sunset Harbor Partner, L.L.C.)
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
Samples: Cedar Shopping Centers Inc, Cedar Shopping Centers Inc
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
Samples: Limited Liability Company Agreement, Limited Liability Company 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 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
Samples: And Restated Agreement (Foundation Capital Resources Inc), Foundation Capital Resources 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
Samples: Agreement (HTS-Sunset Harbor Partner, L.L.C.), Agreement (HTS-Sunset Harbor Partner, L.L.C.)
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 Deductions are attributable in accordance with Section 1.704-2(b)(4) and 1.704-2(i)(12(i)(l) of the Regulations).
Appears in 2 contracts
Samples: Hospital of Fulton, Inc., Winder HMA, 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 Regulations section 1.704-2(i)(1) of the Regulations).
Appears in 2 contracts
Samples: 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
Samples: Limited Partnership Agreement (Inergy Storage, Inc.), Limited Partnership Agreement (Inergy Storage, 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
Samples: 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 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
Samples: Agreement, gentrymillscapital.com
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
Samples: Lease Agreement (Lyondell Chemical Co), Lease Agreement (Equistar Chemicals 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 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
Samples: LXP Industrial Trust, Lepercq Corporate Income Fund L P
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
Samples: Limited Partnership Agreement (New Gaming Capital Partnership), Lexreit Properties 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
Samples: 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 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
Samples: Limited Partnership Agreement (National Patent Development Corp), Limited Partnership Agreement (National Patent Development 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 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
Samples: Limited Partnership Agreement (Silvercrest Asset Management Group Inc.), Limited Partnership Agreement (Silvercrest Asset Management 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 1 contract
Samples: CNL American Properties Fund 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 Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Regulations § 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 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. This Section 5.3.7 is intended to comply with the requirements of Regulations Section 1.704-2(i)(1) of the Regulations).
Appears in 1 contract
Samples: 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 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
Samples: Manufactured Home Communities Inc
Partner Nonrecourse Deductions. Any Partner Nonrecourse ------------------------------- Deductions for any fiscal 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
Samples: Limited Partnership Agreement (North American Natural Gas Inc)
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 1 contract
Samples: Limited Partnership Agreement
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) as 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 1 contract
Samples: Strategic Timber 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 Sections 1.704-2(b)(4) and Deductions are attributable in accordance with Treasury Regulations §1.704-2(i)(1) of the Regulations).
Appears in 1 contract
Samples: 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 Regulations §1.704-2(b)(42 (i) and 1.704-2(i)(1) of the Regulations(1).
Appears in 1 contract
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions Any partner nonrecourse deductions for any fiscal year or other applicable period shall be allocated to the Member who bears the risk of loss with respect to a the loan to which such partner nonrecourse deduction is attributable in accordance with Regulations Section 1.704-2(i), if such sections of the Regulations become applicable to the Company. Partner Nonrecourse Debt nonrecourse debt minimum gain shall be specially allocated charged back to the Partner that bears the economic risk of loss for such Partner Nonrecourse Debt (as determined under Sections Members in accordance with Regulations Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i)(4).
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 bears the economic risk of loss for with respect to the loan 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 1 contract
Samples: Wcof, 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 which such Partner Nonrecourse Debt (as Deductions are attributable(as determined under Sections 1.704-2(b)(4) and in accordance with Section 1.704-2(i)(1) of the Regulations).
Appears in 1 contract
Samples: Procaccianti Hotel Reit, 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 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 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 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 1 contract
Samples: Limited Liability Company Agreement (Industrial Property Trust 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 1 contract
Samples: Limited Partnership Agreement (RMH Teleservices 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 Sections 1.704-2(b)(4) and 1.704-2(i)(1) of the RegulationsDeductions are attributable in accordance with Regulations Section 1.704–2(i)(1).
Appears in 1 contract
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 Regulations Section 1.704-2(b)(4) and 1.704-2(i)(1) of the Regulations2(i).
Appears in 1 contract
Samples: Rw Holdings NNN Reit, Inc.
Partner Nonrecourse Deductions. All 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 under Regulations Section 1.752-2 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
Partner Nonrecourse Deductions. Any 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 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-Deductions are attributable in accordance with Regulations ss. 1.704- 2(i)(1) of the Regulations).
Appears in 1 contract
Samples: Macklowe Properties Inc
