Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Partnership Year shall be specially allocated to the Holders in accordance with their respective Percentage Interests. Any Partner Nonrecourse Deductions for any Partnership Year shall be specially allocated to the Holder(s) 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 Regulations Section 1.704-2(i).
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Holders in accordance with their respective Percentage Interests. Any Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Holder(s) 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 Regulations section 1.704-2(i).
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Partnership Year shall be specially allocated to the Holders of OP Units in accordance with their OP Units. Any Partner Nonrecourse Deductions for any Partnership Year shall be specially allocated to the Holder(s) 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 Regulations Section 1.704-2(i).
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Partners in accordance with their respective Percentage Interest in Common Partnership Interests. Any Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Partner(s) 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 Treasury Regulation Section 1.704-2(b)(4) and 1.704-2(i).
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any nonrecourse deductions (as defined in Reg. §§ 1.704-2(b)(1) and 1.704-2(c)) for any Fiscal Year shall be specially allocated to the Members in accordance with their Percentage Interests. Any partner nonrecourse deductions (as defined in Reg. § 1.704-2(i)) for any Fiscal Year shall be specially allocated to the Member(s) who bear(s) the economic risk of loss (within the meaning of Reg. § 1.752-2) with respect to the partner nonrecourse debt to which such partner nonrecourse deductions are attributable, in accordance with Reg. § 1.704-2(i).
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any --------------------------------------------------------- Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Holders of Partnership Units in accordance with their respective shares of the Nonrecourse Liabilities of the Partnership, determined in accordance with Section 1.752-3 of the Treasury Regulations. Any Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Unitholder(s) 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 1.7042(i) of the Treasury Regulations.
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Partnership taxable year generally shall be allocated to the Partners in accordance with their Partnership Interests; provided, however, that the General Partner may allocate Nonrecourse Deductions in a different manner so long as such allocation is reasonably consistent with allocations of some other significant Partnership item attributable to the Property securing the relevant Nonrecourse Liability that have substantial economic effect in accordance with Regulations Section 1.702-2(e)(2). Any Partner Nonrecourse Deductions for any Partnership taxable year shall be specially allocated to the Partner(s) 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 Regulations Sections 1.704-2(b)(4) and 1.704-2(i).
Nonrecourse Deductions and Partner Nonrecourse Deductions. (i) Nonrecourse Deductions shall be allocated to the Partners and/or Unit Holders in accordance with their Sharing Ratios. For purposes of this Section 3.3(f), “Sharing Ratios” means 21% to the Managing General Partner and 79% to the Investor Partners in proportion to the number of outstanding Units held by each.
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Fiscal Year shall be attributed to the Divisions in accordance with the principles of Article 11.2(c) and allocated between the Members in the same manner that the Net Profits of such Division are allocated under Article 11.1. Any Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member(s) 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 Treasury Regulation Section 1.704-2(i).
Nonrecourse Deductions and Partner Nonrecourse Deductions. For purposes of making the allocations set forth in Articles 11.2(a)(iii), debt shall first be allocated among the Divisions on the basis of the use of the proceeds of such debt (or, if debt cannot be allocated among the Divisions on such basis, on such other basis as the Board of Managers reasonably determines) and the deductions attributable to such debt shall be attributed to the corresponding Division.
