Partnership Nonrecourse Liabilities definition

Partnership Nonrecourse Liabilities means any nonrecourse liabilities (or portions thereof) of the Partnership for which no Partner bears the economic risk of loss.
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Partnership Nonrecourse Liabilities has the meaning assigned to the term “nonrecourse liability” in Treasury Regulation Section 1.752-1(a)(2).
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Examples of Partnership Nonrecourse Liabilities in a sentence

  • The intended effect of using the "remedial method" described in Regulation Section 1.704-3(d) shall be that the Upper Tier Limited Partnership shall receive an allocation of Partnership Nonrecourse Liabilities that on the date hereof is not less than $380,000,000.

  • Any Partnership Minimum Gain allocated pursuant to this Section 16.4(b)(i) shall consist of first, gains recognized from the disposition of Partnership Property subject to one or more Partnership Nonrecourse Liabilities, and second, if necessary, a pro rata portion of the Partnership's other items of income or gain for that year.

  • It is the intent that this new supervisory union would be called the Washington Caledonia Supervisory Union and result in the consolidation of two existing administrative central offices currently serving two separate Supervisory Unions, resulting in the creation of a single central office serving both new unified union school districts.

  • Partnership Agreement if there is a net decrease during the Partnership Fiscal Year in Minimum Gain attributable to Partnership Nonrecourse Liabilities, each Partner shall be allocated Gross Income for such Fiscal Year (and, if necessary, for subsequent years) in proportion to and to the extent of such Partner’s Chargeback Amount calculated with respect only to Partnership Nonrecourse Liabilities.

  • Partners' Partnership Non-recourse Liabilities 68 11.10 Tax Allocations: Code Section 704(c) 69 11.11.

  • If for any Fiscal Year or other relevant period of the Partnership there is a net decrease in Minimum Gain attributable to Partnership Nonrecourse Liabilities, each Partner shall be allocated items of Partnership income and gain for such year or period (and, if necessary, for subsequent Fiscal Years or periods) in an amount equal to such Partner’s share of such net decrease, as determined in accordance with Treasury Regulations Sections 1.704-2(f) and (g).

  • For any Partnership Fiscal Year, the determination of the items of Partnership loss, deduction and Code Section 705(a)(2)(B) expenditure that constitute nonrecourse deductions attributable to Partner Nonrecourse Liabilities must be made before determining which deductions constitute nonrecourse deductions with respect to Partnership Nonrecourse Liabilities.

  • The effect of using the "remedial method" described in Regulation Section 1.704-3(d) shall be that the Limited Partner shall receive an allocation of Partnership Nonrecourse Liabilities that on the date hereof is not less than $129,700,000.

  • Any Partnership Minimum Gain allocated pursuant to this Section 5.2(d)(1)(A) shall consist of first, gains recognized from the Disposition of Partnership property subject to one or more Partnership Nonrecourse Liabilities, and second, if necessary, a pro rata portion of the Partnership’s other items of income or gain for such Fiscal Year.

  • Nonrecourse liabilities include Partnership Nonrecourse Liabilities and Partner Nonrecourse Liabilities.

Related to Partnership Nonrecourse Liabilities

  • Nonrecourse Liabilities has the meaning set forth in Section 1.704-2(b)(3) of the Regulations.

  • Nonrecourse Liability has the meaning set forth in Treasury Regulation Section 1.752-1(a)(2).

  • Recourse Liabilities means the amount of liabilities owed by the Partnership (other than Nonrecourse Liabilities and liabilities to which Partner Nonrecourse Deductions are attributable in accordance with Section 1.704-(2)(i) of the Regulations).

  • Member Nonrecourse Debt Minimum Gain means an amount, with respect to each Member Nonrecourse Debt, equal to the Company Minimum Gain that would result if such Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Regulations Section 1.704-2(i)(3).

  • Partner Nonrecourse Debt Minimum Gain has the meaning set forth in Treasury Regulation Section 1.704-2(i)(2).

  • Member Nonrecourse Debt has the meaning of “partner nonrecourse debt” set forth in Treasury Regulations Section 1.704-2(b)(4).

  • Partner Nonrecourse Debt has the meaning set forth in Treasury Regulation Section 1.704-2(b)(4).

  • Member Nonrecourse Deductions has the meaning of “partner nonrecourse deductions” set forth in Treasury Regulations Sections 1.704-2(i)(1) and 1.704-2(i)(2).

  • Nonrecourse Built-in Gain means with respect to any Contributed Properties or Adjusted Properties that are subject to a mortgage or pledge securing a Nonrecourse Liability, the amount of any taxable gain that would be allocated to the Partners pursuant to Section 6.2(b) if such properties were disposed of in a taxable transaction in full satisfaction of such liabilities and for no other consideration.

  • Member Nonrecourse Deduction has the meaning assigned to the term “partner nonrecourse deduction” in Treasury Regulation Section 1.704-2(i)(1).

  • Nonrecourse Debt means any Company liability to the extent that no Member or related Person bears the economic risk of loss for such liability under Section 1.752-2 of the Treasury Regulations.

  • Partner Nonrecourse Deductions means any and all items of loss, deduction or expenditure (including any expenditure described in Section 705(a)(2)(B) of the Code) that, in accordance with the principles of Treasury Regulation Section 1.704-2(i), are attributable to a Partner Nonrecourse Debt.

  • Nonrecourse Indebtedness means, with respect to a Person, an Extension of Credit or other Indebtedness in respect of which recourse for payment (except for customary exceptions for fraud, misapplication of funds, environmental indemnities, and other similar customary exceptions to recourse liability) is contractually limited to specific assets of such Person encumbered by a Lien securing such Extension of Credit or other Indebtedness.

  • Partnership Minimum Gain has the meaning set forth in Regulations Section 1.704-2(b)(2), and the amount of Partnership Minimum Gain, as well as any net increase or decrease in Partnership Minimum Gain, for a Partnership Year shall be determined in accordance with the rules of Regulations Section 1.704-2(d).

  • Nonrecourse Obligation means indebtedness or other obligations substantially related to (i) the acquisition of assets not previously owned by the Company or any Restricted Subsidiary or (ii) the financing of a project involving the development or expansion of properties of the Company or any Restricted Subsidiary, as to which the obligee with respect to such indebtedness or obligation has no recourse to the Company or any Restricted Subsidiary or any assets of the Company or any Restricted Subsidiary other than the assets which were acquired with the proceeds of such transaction or the project financed with the proceeds of such transaction (and the proceeds thereof).

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

  • Nonrecourse Deductions has the meaning set forth in Section 1.704-2(b)(1) of the Regulations.

  • Member Minimum Gain means an amount, with respect to each Member Nonrecourse Debt, equal to the Company Minimum Gain that would result if such Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Regulations Section 1.704-2(i)(3).

  • Partner Minimum Gain means an amount, with respect to each Partner Nonrecourse Debt, equal to the Partnership Minimum Gain that would result if such Partner Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Regulations Section 1.704-2(i)(3).

  • Common expense liability means the liability for common

  • Minimum Gain means “partnership minimum gain” determined pursuant to Treasury Regulation Section 1.704-2(d).

  • Company Minimum Gain has the meaning given the term “partnership minimum gain” in Sections 1.704-2(b)(2) and 1.704-2(d) of the Regulations.

  • Capitalized Lease Liabilities means all monetary obligations of the Borrower or any of its Subsidiaries under any leasing or similar arrangement which, in accordance with GAAP, would be classified as capitalized leases, and, for purposes of this Agreement and each other Loan Document, the amount of such obligations shall be the capitalized amount thereof, determined in accordance with GAAP, and the stated maturity thereof shall be the date of the last payment of rent or any other amount due under such lease prior to the first date upon which such lease may be terminated by the lessee without payment of a penalty.

  • Recourse Debt means Indebtedness that is not Non-Recourse Indebtedness.

  • Partnership Percentage means the percentage share of each Partner in the Net Income or Net Loss of the Partnership. The Partners’ initial Partnership Percentages shall be proportionate to the Partners’ initial Capital Contributions to the Partnership. Thereafter, subject to Section 1.68(g), such Partnership Percentages shall be adjusted only to reflect a disproportionate Capital Contribution by one or more Partners or a disproportionate distribution to one or more Partners, with disproportion being determined in accordance with Sections 4.2(a) and 4.5(b), except as set forth in Section 1.68(f).

  • Partnership Year means the fiscal year of the Partnership, which shall be the calendar year.