Nonrecourse Deduction definition

Nonrecourse Deduction shall have the meaning given such term in Regulations Section 1.704-2(b)(1).
Nonrecourse Deduction has the meaning assigned to that term in Treasury Regulation Section 1.704-2(b).
Nonrecourse Deduction means a deduction for spending that is funded out of nonrecourse borrowing by the Company or that is otherwise attributable to a “nonrecourse liabilityof the Company within the meaning of Treasury Regulations Section 1.704-2.

Examples of Nonrecourse Deduction in a sentence

  • Each Nonrecourse Deduction of the Company shall be specially allocated among the Common Members in accordance with their Unit Percentages.

  • Indeed, I respectfully submit that they are plainly unsatisfactory.It is also interesting to note that in the case of Ziegler,88 the Court of Justice had to consider a claim that it was improper for the Commission both to impose a penalty on a cartel and at the same time to claim damages for hav- ing had to pay too much to members of the cartel.

  • Any Qualified Income Offset, Gross Income Allocation, Nonrecourse Deduction, Member Nonrecourse Deductions, Member Minimum Gain Chargeback, Minimum Gain Chargeback, Code Section 704(c) allocations, or other amount shall be specially allocated under Sections 5.04, 5.05, 5.06, 5.07, 5.08, 5.09, 5.10, 5.11 and 5.12 before any other allocations, and the Minimum Gain Chargebacks shall be the first allocations made.

  • Any Member Nonrecourse Deduction will be allocated to the Member who bears the risk of loss with respect to the loan to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation § 1.704-2(i).

  • If more than one Member bears the economic risk of loss for a Member Nonrecourse Debt, any Member Nonrecourse Deduction attributable thereto shall be allocated to the Members in accordance with the ratios in which they share such risk of loss.


More Definitions of Nonrecourse Deduction

Nonrecourse Deduction has the meaning set forth in Treasury Regulations Sections 1.704-2(b)(1) and 1.704-2(c).
Nonrecourse Deduction means, subject to Section 5.02 of this Appendix, a nonrecourse deduction determined pursuant to Treas. Reg. §1.704-2(b)(1) and Treas. Reg. §1.704-2(c).
Nonrecourse Deduction means a nonrecourse deduction determined pursuant to Treasury Regulations § 1.704-2(c).
Nonrecourse Deduction means any and all items of loss, deduction or expenditure (described in Section 705(a) (2) (B) of the Code) that, in accordance with the principles of Treasury Regulation Section 1.704-2(b)(1) and 1.704-2(c), are attributable to a Nonrecourse Liability.
Nonrecourse Deduction shall have the same meaning as nonrecourse deductions set forth in Treasury Regulation § 1.704-2. Generally, the amount of Nonrecourse Deductions for a fiscal year equals the net increase in the amount of Partnership Minimum Gain (determined in accordance with Treasury Regulation § 1.704-2(d)) during such year reduced (but not below zero) by the aggregate distributions made during the year of proceeds of a Nonrecourse Liability that are allocable to an increase in Partnership Minimum Gain, determined according to the provisions of Treasury Regulation § 1.704-2(c) and (h).
Nonrecourse Deduction means a nonrecourse deduction determined pursuant to Treasury Regulations Section 1.704-2(c).
Nonrecourse Deduction has the meaning set forth in Regulations Section 1.704-2(b)(1), and the amount of Nonrecourse Deductions for a Partnership Year shall be determined in accordance with the rules of Regulations Section 1.704-2(c).