Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions (as defined under Regulation Section 1.704-2(i)(2)) shall be allocated pursuant to Regulation Section 1.704-2(i) to the Member who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which it is attributable.
Appears in 7 contracts
Samples: Operating Agreement (Strategic Realty Trust, Inc.), Operating Agreement (Strategic Realty Trust, Inc.), Operating Agreement (Wellsford Real Properties Inc)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions (attributable to otherwise nonrecourse debt with respect to which a Partner or a related person of a Partner described in Regulations Section 1.752-2(c) is the creditor or otherwise bears the "economic risk of loss" as defined under Regulation in Regulations Section 1.7041.752-2(i)(2)2(b) shall be allocated pursuant to Regulation Section 1.704-2(i) to the Member who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which it is attributablesuch Partner.
Appears in 5 contracts
Samples: Ecoscience Corp/De, Cogentrix Energy Inc, Cogentrix Energy Inc
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions nonrecourse deductions (as defined under in Regulation Section §1.704-2(i)(1) and §1.704-2(i)(2)) for any Year shall be specially allocated pursuant to Regulation Section 1.704-2(i) to the Member Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt nonrecourse debt to which it is attributablesuch Partner nonrecourse deductions are attributable in accordance with Regulation §1.704-2(i)(l).
Appears in 4 contracts
Samples: MPT of West Anaheim, LLC, MPT of West Anaheim, LLC, MPT of West Anaheim, LLC
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions (as defined under Regulation Section 1.704-2(i)(2)) Deduction shall be allocated pursuant to Regulation Section 1.704-2(i) to the Member Partner who bears the economic risk of loss with respect to the loan to which such Partner Nonrecourse Debt to which it is attributableDeductions are attributable in accordance with Treasury Regulation § 1.704-2(i).
Appears in 4 contracts
Samples: Limited Partnership Agreement (Innsuites Hospitality Trust), Agreement (BuyDebtCo, LLC), Limited Partnership Agreement (CorEnergy Infrastructure Trust, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions (as defined under Regulation Section 1.704-2(i)(2)) shall be allocated pursuant among the Members in accordance with the ratios in which the Members share the economic risk of loss for the Partner Nonrecourse Debt that gave rise to those deductions. This allocation is intended to comply with the requirements of Regulation Section 1.704-2(i) to the Member who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which it is attributableand shall be interpreted and applied consistently therewith.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Phillips 66 Partners Lp), Limited Liability Company Agreement (Phillips 66 Partners Lp), Governance Agreement (Phillips Petroleum Co)
Partner Nonrecourse Deductions. Any “Partner Nonrecourse Deductions nonrecourse deductions” (as defined under Regulation Section 1.704-2(i)(2)) shall be allocated pursuant to Regulation within the meaning of Section 1.704-2(i) of the Regulations) shall be allocated to the Member Owner who bears the economic risk of loss associated with respect to such deductions, in accordance with Section 1.704-2(i) of the Partner Nonrecourse Debt to which it is attributableRegulations.
Appears in 3 contracts
Samples: Operating Agreement (Sg Blocks, Inc.), Operating Agreement (Safe & Green Development Corp), Operating Agreement (Safe & Green Development Corp)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions nonrecourse deductions (as defined under in Regulation Section §1.704-2(i)(1) and §1.704-2(i)(2)) for any Year shall be specially allocated pursuant to Regulation Section 1.704-2(i) to the Member Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt nonrecourse debt to which it is attributablesuch Partner nonrecourse deductions are attributable in accordance with Regulation § 1.704-2(i)(1).
Appears in 2 contracts
Samples: Agreement (MPT of West Anaheim, LLC), MPT of West Anaheim, LLC
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions nonrecourse deductions (as defined under in Regulation Section §1.704-2(i)(l) and §1.704-2(i)(2)) for any Year shall be specially allocated pursuant to Regulation Section 1.704-2(i) to the Member Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt nonrecourse debt to which it is attributablesuch Partner nonrecourse deductions are attributable in accordance with Regulation §1.704-2(i)(l).
Appears in 2 contracts
Partner Nonrecourse Deductions. Any The Partner Nonrecourse Deductions of the Venturer (as defined determined under Regulation Section section 1.704-2(i)(2)) shall be allocated pursuant to Regulation Section 1.704-2(i) each year to the Member who Venturer that bears the economic risk of loss (within the meaning of Regulation section 1.752-2) with respect to the Partner Nonrecourse Debt to which it is such Partner Nonrecourse Deductions are attributable.
Appears in 2 contracts
Samples: Joint Venture Agreement (Core Resource Management, Inc.), Joint Venture Agreement (TransCoastal Corp)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions partner nonrecourse deductions (as defined under Regulation in Treasury Regulations Section 1.704-2(i)(22(i)(1)) shall be allocated pursuant to Regulation Section 1.704-2(i) to the Member who (in its capacity, directly or indirectly, as lender, guarantor or otherwise) bears the economic risk of loss with respect to the Partner Nonrecourse Debt loan to which it is attributablesuch partner nonrecourse deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Petrohawk Energy Corp), Operating Agreement (Atlantic Power Corp)
Partner Nonrecourse Deductions. Any The Partner Nonrecourse Deductions nonrecourse deductions (as defined determined under Regulation Regulations Section 1.704-2(i)(2)) shall be allocated pursuant to Regulation Section 1.704-2(i) each year to the Member who Partner that bears the economic risk of loss with respect to (within the meaning of Regulations Section 1.752-2) for the Partner Nonrecourse Debt nonrecourse debt to which it is attributablesuch Partner nonrecourse deductions are attributable in accordance with Regulations Section 1.704‑2(i)(1).
Appears in 1 contract
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions (as defined under Regulation Section 1.704-1.704- 2(i)(2)) shall be allocated pursuant to Regulation Section 1.704-1.704- 2(i) to the Member who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which it is attributable.
Appears in 1 contract
Samples: Operating Agreement (Wellsford Real Properties Inc)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions partner nonrecourse deductions (as defined under Regulation in Regulations Section 1.704-2(i)(22(i)(1)) shall be allocated pursuant to Regulation Section 1.704-2(i) to the Member Partner who (in its capacity, directly or indirectly, as lender, guarantor or otherwise) bears the economic risk of loss with respect to the Partner Nonrecourse Debt loan to which it is attributablesuch partner nonrecourse deductions are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 1 contract
Samples: Limited Partnership Agreement (Inland Real Estate Corp)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions nonrecourse deductions (as defined under in Regulation Section §1.704-2(i)(l) and §1.704-2(i)(2)) for any Year shall be specially allocated pursuant to Regulation Section 1.704-2(i) to the Member Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt nonrecourse debt to which it is attributablesuch Partner nonrecourse deductions are attributable in accordance with Regulation §1.704-2(i)(1).
Appears in 1 contract
Samples: MPT of West Anaheim, LLC
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions (as defined under Regulation Section 1.704-2(i)(2)) shall be specially allocated pursuant to Regulation Section 1.704-2(i) to the Member who Partner that bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which it is attributablethe deductions are allocable in accordance with Regulation Section 1.704-2(i)(1).
Appears in 1 contract
Samples: Limited Partnership Agreement (Carter Validus Mission Critical REIT, Inc.)
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions nonrecourse deductions (as defined under in Regulation Section §1.704-2(i)(l) and §1.704-2(i)(2)) for any Year shall be specially allocated pursuant to Regulation Section 1.704-2(i) to the Member Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt nonrecourse debt to which it is attributablesuch Partner nonrecourse deductions are attributable in accordance with Regulation § 1.704-2(i)(1).
Appears in 1 contract
Samples: MPT of West Anaheim, LLC
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions (as defined under Regulation Section 1.704-2(i)(2)) shall be allocated pursuant to Regulation Section Regulations section 1.704-2(i2(b)(4) and (i)(1) to the Member Partner or Partners who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which it is attributablesuch deductions.
Appears in 1 contract
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions nonrecourse deductions (as defined under in Regulation Section §1.704-2(i)(1) and § 1.704-2(i)(2)) for any Year shall be specially allocated pursuant to Regulation Section 1.704-2(i) to the Member Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt nonrecourse debt to which it is attributablesuch Partner nonrecourse deductions are attributable in accordance with Regulation §1.704-2(i)(1).
Appears in 1 contract
Samples: MPT of West Anaheim, LLC
Partner Nonrecourse Deductions. Any Partner Nonrecourse Deductions (as defined under Regulation Section 1.704-2(i)(2)) shall be allocated pursuant to Regulation Section 1.704-2(i2(b)(4) and (i)(1) of the Treasury Regulations to the Member Partner who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which it is attributabledeductions.
Appears in 1 contract
