Nonrecourse Deduction definition

Nonrecourse Deduction has the meaning assigned to that term in Treasury Regulation Section 1.704-2(b).

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Nonrecourse Deduction shall have the meaning given such term in Regulations Section 1.704-2(b)(1).

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 liability” of the Company within the meaning of Treasury Regulations Section 1.704-2.

Examples of Nonrecourse Deduction in a sentence

• Any Member Loan Nonrecourse Deduction for any taxable year or other period shall be specially allocated to the Interest Holder who bears the risk of loss with respect to the loan to which the Member Loan Nonrecourse Deduction is attributable in accordance with Regulation Section 1.704-2(b).

• Notwithstanding any provision of the Partnership Agreement to the contrary, any Partner Nonrecourse Deduction for any fiscal year or other 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 Section 1.704-2(i) of the Treasury Regulations.

• Each Nonrecourse Deduction of the Company shall be specially allocated to the Members in a manner determined in good faith by the Managing Member taking into account the relative economic interests of the Members of the Company.

• Notwithstanding any other provisions of the Agreement, any item of Member Nonrecourse Deduction with respect to a Member Nonrecourse Debt shall be allocated to the Member or Members who bear the economic risk loss for such Member Nonrecourse Debt in accordance with Treas.

• Any Partner Nonrecourse Deduction for any fiscal year or other 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 Section 1.704-2(i) of the Treasury Regulations.

More Definitions of Nonrecourse Deduction

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 the meaning set forth in Treasury Regulation Sections 1.704-2(b)(1) and 1.704-2(c).

Nonrecourse Deduction means a nonrecourse deduction determined pursuant to Treasury Regulations § 1.704-2(c).

Nonrecourse Deduction means a nonrecourse deduction determined pursuant to Treasury Regulations Section 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 Treas. Reg. § 1.704-2(b)(1) and Treas. Reg. § 1.704-2(c).