Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any taxable period shall be allocated to the Member who bears the economic risk of loss with respect to the liability to which such Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j).
Appears in 7 contracts
Samples: Limited Liability Company Agreement (Exeter Finance Corp), Limited Liability Company Agreement (Theravance Inc), Limited Liability Company Agreement (Theravance Biopharma, Inc.)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any taxable period shall be allocated to the Member Partner who bears the economic risk of loss with respect to the liability to which such Partner Nonrecourse Deductions are attributable in accordance with U.S. Treasury Regulations Section 1.704-2(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 (Apollo Realty Income Solutions, Inc.)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any taxable period shall be allocated to the Member Partner who bears the economic risk of loss with respect to the liability to which such Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j2(i).
Appears in 4 contracts
Samples: Investment Management Agreement (Blackstone Infrastructure Strategies L.P.), Investment Management Agreement (Blackstone Infrastructure Strategies L.P.), Limited Partnership Agreement (Blackstone Private Equity Strategies Fund L.P.)
Partner Nonrecourse Deductions. Notwithstanding anything to the contrary in this Agreement, any Partner Nonrecourse Deductions for any taxable year or other period shall for which allocations are made will be allocated to the Member who bears the economic risk of loss with respect to the liability to which such the Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j2(i).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Wells Real Estate Investment Trust Inc), Limited Liability Company Agreement (Wells Real Estate Investment Trust Inc)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any taxable period shall be allocated to the Member Partner who bears the economic risk of loss with respect to the liability to which such Partner Nonrecourse Deductions are attributable in accordance with U.S. Treasury Regulations Section 1.704-2(j). “Partner Nonrecourse Deductions” shall have the meaning specified in U.S. Treasury Regulations Section 1.704-2(i)(2).
Appears in 2 contracts
Samples: Limited Partnership Agreement (North Haven Net REIT), Limited Partnership Agreement (North Haven Net REIT)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any taxable period shall be allocated to the Member who bears the economic risk of loss with respect to the liability to which such Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Adeptus Health Inc.), Limited Liability Company Agreement (Adeptus Health Inc.)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any taxable period shall be allocated to the Member Partner who bears the economic risk of loss with respect to the liability to which such Partner Nonrecourse Deductions are attributable in accordance with U.S. Treasury Regulations Section 1.704-2(j). "Partner Nonrecourse Deductions" has the meaning specified in U.S. Treasury Regulations Section 1.704-2(i)(2).
Appears in 2 contracts
Samples: Limited Partnership Agreement (Apollo Realty Income Solutions, Inc.), Limited Partnership Agreement (Apollo Realty Income Solutions, Inc.)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any taxable period shall be allocated to the Member who Partner that bears the economic risk of loss with respect to the liability Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j)2(1) of the Regulations.
Appears in 2 contracts
Samples: Limited Partnership Agreement (Exterran Energy Solutions, L.P.), Limited Partnership Agreement (Exterran Energy Solutions, L.P.)
Partner Nonrecourse Deductions. Notwithstanding anything to the contrary in this Agreement, any Partner Nonrecourse Deductions for any taxable year or other period shall for which allocations are made will be allocated to the Member Partner or Assignee who bears the economic risk of loss with respect to the liability to which such the Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j1.704- 2(i).
Appears in 1 contract
Samples: Bay Apartment Communities Inc
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any taxable period shall be allocated to the Member Partner who bears the economic risk of loss with respect to the liability to which such Partner Nonrecourse Deductions are attributable in accordance with U.S. Treasury Regulations Section 1.704-2(j2(i)(1). “Partner Nonrecourse Deductions” has the meaning specified in U.S. Treasury Regulations Section 1.704-2(i)(2).
Appears in 1 contract
Samples: Limited Partnership Agreement (KBS Real Estate Investment Trust III, Inc.)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any taxable period shall be allocated to the Member who bears the economic risk of loss with respect to the liability to which such Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j1.704‑2(j).
Appears in 1 contract
Samples: Limited Liability Company Agreement (pdvWireless, Inc.)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any taxable period shall be allocated to the Member Partner who bears the economic risk of loss with respect to the liability to which such Partner Nonrecourse Deductions are attributable in accordance with United States Treasury Regulations Section 1.704-2(j).
Appears in 1 contract
Samples: Limited Partnership Agreement (Corsair Capital LLC)
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any taxable period shall be allocated to the Member Partner who bears the economic risk of loss with respect to the liability to which such Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j2(i)(1).
Appears in 1 contract
Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any taxable period shall be allocated to the Member Partner who bears the economic risk of loss with respect to the liability to which such Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j). “Partner Nonrecourse Deductions” has the meaning specified in Regulations Section 1.704- 2(i)(2).
Appears in 1 contract
Samples: Limited Partnership Agreement (Oak Street Net Lease Trust)
