Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 62 contracts
Samples: Agreement (CNL Income Mesa Del Sol, LLC), Limited Partnership Agreement (Nexpoint Diversified Real Estate Trust), Limited Partnership Agreement (NexPoint Real Estate Finance, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year Year shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section Sections 1.704-2(b)(4) and 1.704-2(i).
Appears in 32 contracts
Samples: Limited Partnership Agreement (Forest City Enterprises Inc), Fourth (Gramercy Property Trust Inc.), Limited Partnership Agreement (Forest City Realty Trust, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year period shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt liability to which such Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i2(j).
Appears in 26 contracts
Samples: Limited Partnership Agreement (Beneficient), Limited Partnership Agreement (Fifth Street Asset Management Inc.), Limited Partnership Agreement (Summit Materials, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year period shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt liability to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i2(j). “Partner Nonrecourse Deductions” has the meaning specified in Regulations Section 1.704-2(i)(2).
Appears in 25 contracts
Samples: Limited Partnership Agreement (Invesco Real Estate Income Trust Inc.), Agreement (Starwood Real Estate Income Trust, Inc.), Limited Partnership Agreement (Invesco Real Estate Income Trust Inc.)
Partner Nonrecourse Deductions. Any Notwithstanding anything to the contrary in this Agreement, any Partner Nonrecourse Deductions for any Partnership taxable year shall or other period for which allocations are made will be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt liability to which such the Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i).
Appears in 24 contracts
Samples: Limited Partnership Agreement (First Industrial Lp), Limited Partnership Agreement (First Industrial Realty Trust Inc), Registration Rights Agreement (First Industrial Realty Trust Inc)
Partner Nonrecourse Deductions. Any The Partner Nonrecourse Deductions for any of the Partnership taxable year (as determined under Regulations Section 1.704-2(i)(2)) shall be specially allocated each year to the Partner who that bears the economic risk of loss (within the meaning of Regulations Section 1.752-2) with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)attributable.
Appears in 10 contracts
Samples: Limited Partnership Agreement (O'Donnell Strategic Industrial REIT, Inc.), Limited Partnership Agreement (Moody National REIT I, Inc.), Limited Partnership Agreement (TNP Strategic Retail Trust, Inc.)
Partner Nonrecourse Deductions. Any Notwithstanding anything to the contrary in this Agreement, any Partner Nonrecourse Deductions for any Partnership taxable year shall or other period for which allocations are made will be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such the Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 9 contracts
Samples: AmREIT Monthly Income & Growth Fund IV LP, AmREIT Monthly Income & Growth Fund III LTD, AmREIT Monthly Income & Growth Fund IV LP
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year (or portion thereof) of the Up Trust shall be specially allocated to the Partner Holder who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable attributable, in accordance with Regulations Section 1.704-2(i)2.
Appears in 9 contracts
Samples: Trust Agreement (MACRO Securities Depositor, LLC), Trust Agreement (MacroShares Major Metro Housing Up Trust), Trust Agreement (MacroShares $100 Oil Up Trust)
Partner Nonrecourse Deductions. Any Notwithstanding anything to the contrary in this Agreement, any Partner Nonrecourse Deductions for any Partnership taxable year shall or other period for which allocations are made will be specially allocated to the Partner Member who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such the Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 9 contracts
Samples: Limited Liability Company Agreement (DCT Chino LLC), Truck Business Relationship Agreement (Navistar International Corp), Operating Agreement (Caterpillar Inc)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year period shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt liability to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i2(j).
Appears in 8 contracts
Samples: Limited Partnership Agreement (EQT Exeter Real Estate Income Trust, Inc.), Limited Partnership Agreement (Sculptor Diversified Real Estate Income Trust, Inc.), Limited Partnership Agreement (EQT Exeter Real Estate Income Trust Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year period shall be specially allocated to the Partner Member who bears the economic risk of loss with respect to the Partner Nonrecourse Debt liability to which such Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i2(j).
Appears in 7 contracts
Samples: Limited Liability Company Agreement (Highbury Financial Inc), Limited Liability Company Agreement (Evercore Partners Inc.), Limited Liability Company Agreement (Exeter Finance Corp)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i2(i)(1).
Appears in 7 contracts
Samples: Limited Partnership Agreement (Safeway Stores 42, Inc.), Limited Partnership Agreement (Safeway Stores 42, Inc.), Limited Partnership Agreement (Safeway Stores 42, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year period shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt liability to which such Partner Nonrecourse Deductions are attributable in accordance with U.S. Treasury Regulations Section 1.704-2(i2(j). “Partner Nonrecourse Deductions” has the meaning specified in U.S. Treasury Regulations Section 1.704-2(i)(2).
Appears in 7 contracts
Samples: Limited Partnership Agreement (Blackstone Real Estate Income Trust, Inc.), Limited Partnership Agreement (Blackstone Real Estate Income Trust, Inc.), Limited Partnership Agreement (Blackstone Real Estate Income Trust, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year Year shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i2(i)(2).
Appears in 7 contracts
Samples: Agreement and Plan of Merger (Lexington Realty Trust), Ownership Limit Waiver Agreement (Newkirk Master Lp), Lexington Realty Trust
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year shall be specially allocated to the Partner Member who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i2(i)(1).
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Martin Midstream Partners Lp), Limited Liability Company Agreement (Martin Midstream Partners Lp), Limited Liability Company Agreement (Martin Midstream Partners Lp)
Partner Nonrecourse Deductions. Any Notwithstanding anything to the contrary in this Agreement, any Partner Nonrecourse Deductions for any Partnership taxable year shall or other period for which allocations are made will be specially allocated to the Partner Member who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such the Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i).
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Ranger Energy Services, Inc.), Limited Liability Company Agreement (Ranger Energy Services, Inc.), Limited Liability Company Agreement (Ranger Energy Services, Inc.)
Partner Nonrecourse Deductions. Any Notwithstanding anything to the contrary in this Agreement, any Partner Nonrecourse Deductions for any Partnership taxable year shall or other period for which allocations are made will be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such the Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i).
Appears in 4 contracts
Samples: Cornell Corrections of Rhode Island, Inc., Limited Partnership Agreement (Us Home & Garden Trust I), Partnership Agreement (Easy Gardener Products LTD)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year Year shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 3 contracts
Samples: Mid-America Apartments, L.P., Highwoods Properties Inc, Colonial Realty Limited Partnership
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i).. F.
Appears in 3 contracts
Samples: Gables Realty Limited Partnership, Gables Realty Limited Partnership, Gables Residential Trust
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i2(i)(l).
Appears in 3 contracts
Samples: Limited Partnership Agreement (Safeway Stores 42, Inc.), Limited Partnership Agreement (Safeway Stores 42, Inc.), Limited Partnership Agreement (Safeway Stores 42, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions ------------------------------- for any Partnership taxable year Year shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section Sections 1.704-2(b)(4) and 1.704-2(i).
Appears in 2 contracts
Samples: Host Marriott Trust, Host Marriott L P
Partner Nonrecourse Deductions. ATTRIBUTABLE TO PARTNER NONRECOURSE DEBT. Any Partner Nonrecourse Deductions for any Partnership taxable year Taxable Year or other period shall be specially allocated to the Partner who bears the economic risk Economic Risk of loss Loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section SECTION 1.704-2(i)2 of the Regulations.
Appears in 2 contracts
Samples: Agreement (Access Health Inc), Agreement (Access Health Inc)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i1.704‑2(i).
Appears in 2 contracts
Samples: Prior Agreement (Rouse Properties, Inc.), Prior Agreement (Rouse Properties, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year Year shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i1.704‑2(i)(2).
Appears in 2 contracts
Samples: Lepercq Corporate Income Fund L P, Lexington Realty Trust
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i2(i)(2).
Appears in 1 contract
Samples: Rodamco North America N V
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year Fiscal Year shall be specially specifically allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)2 (i) (1) of the Regulations.
Appears in 1 contract
Samples: O Ray Holdings Inc
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions ------------------------------ for any Partnership taxable year shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 1 contract
Samples: Maryland Property Capital Trust Inc
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year or other period shall be specially allocated to the Partner who bears the economic risk of loss with respect to the liability to which the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are Deduction is attributable in accordance with Regulations Section Treas. Regs. §1.704-2(i).. Appendix “A” - Page 6 APPENDIX “B” TO THE AMENDED AND RESTATED LIMITED PARTNERSHIP AGREEMENT OF THE SAINT XXXX, L.P.
Appears in 1 contract
Samples: Limited Partnership Agreement (Stratus Properties Inc)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year shall be specially allocated to the General Partner or Limited Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section § 1.704-2(i2(i)(l).
Appears in 1 contract
Samples: Certificate and Agreement (HEALTHSOUTH of Toms River, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year Year shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section Sections 1.704-2(6)(4) and 1.704-2(i).
Appears in 1 contract
Samples: Limited Partnership Agreement (Moody National REIT II, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions ------------------------------ for any Partnership taxable year shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 1 contract
Samples: Town & Country Trust
Partner Nonrecourse Deductions. Any Notwithstanding anything to the contrary in this.Agreement, any Partner Nonrecourse Deductions for any Partnership taxable year shall or other period for which allocations are made will be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such the Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i).
Appears in 1 contract
Partner Nonrecourse Deductions. Any Notwithstanding anything to the contrary in this Agreement, any Partner Nonrecourse Deductions for any Partnership taxable year shall or other period for which allocations are made will be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt liability to which such the Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 1 contract
Partner Nonrecourse Deductions. Any Partner Nonrecourse Nonre- course Deductions for any Partnership taxable year shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 1 contract
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year Year shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i2(i)(1).
Appears in 1 contract
Samples: Price Development Co Lp
Partner Nonrecourse Deductions. Any Partner Nonrecourse ------------------------------ Deductions for any Partnership taxable year shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 1 contract
Samples: Reckson Associates Realty Corp
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year shall or other period will be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with principles under Treasury Regulations Section 1.704-2(i).
Appears in 1 contract
Samples: Partnership Interest Purchase Agreement (CNL Income Properties Inc)
Partner Nonrecourse Deductions. Any Notwithstanding anything to the contrary in this Agreement, any Partner Nonrecourse Deductions for any Partnership taxable year shall or other period for which allocations are made will be specially allocated to the Partner Member who bears the economic risk of loss with respect to the Partner Nonrecourse Debt partner nonrecourse debt to which such the Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i).
Appears in 1 contract
Samples: Company Agreement
Partner Nonrecourse Deductions. Any Partner Nonrecourse Nonre-course Deductions for any Partnership taxable year shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 1 contract
Samples: Property Management Agreement (Pacific Gulf Properties Inc)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year shall or other period will be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with principles under Regulations Section 1.704-2(i).
Appears in 1 contract
Samples: Limited Partnership Agreement (CNL Income Properties Inc)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year of the Partnership shall be specially allocated to the Partner who bears the economic risk of loss that made, or guaranteed or is otherwise liable with respect to the Partner Nonrecourse Debt loan to which such Partner Nonrecourse Deductions are attributable in accordance with principles under Treasury Regulations Section 1.704-2(i).
Appears in 1 contract
Samples: Limited Partnership Agreement (Crossroads Systems Inc)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year Fiscal Year or other applicable period shall be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i2(i)(1).
Appears in 1 contract
Samples: Keystone Property Trust
Partner Nonrecourse Deductions. Any Notwithstanding anything to the ------------------------------ contrary in this Agreement, any Partner Nonrecourse Deductions for any Partnership taxable year shall or other period for which allocations are made will be specially allocated to the Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such the Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i).
Appears in 1 contract
Samples: Fiber Glass Systems Lp
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions for any Partnership taxable year shall be specially allocated to the Limited Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 1 contract
Samples: Newkirk Master Lp
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions partner nonrecourse deductions for any Partnership taxable year Taxable Year shall be specially allocated to the Partner Member who bears the economic risk of loss with respect to the Partner Nonrecourse Debt partner nonrecourse debt to which such Partner Nonrecourse Deductions partner nonrecourse deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i2(i)(1).
Appears in 1 contract
Samples: Limited Liability Company Agreement (KC Holdco, LLC)
Partner Nonrecourse Deductions. Any Notwithstanding anything to the contrary in this Agreement, any Partner Nonrecourse Deductions for any Partnership taxable year shall or other period for which allocations are made will be specially allocated to the Partner Member who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such the Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-1.704- 2(i).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Lightstone Real Estate Income Trust Inc.)
