Allocation of Partner Nonrecourse Deductions. Any “partner nonrecourse deductions,” within the meaning of Section 1.704-2(i) of the Regulations, shall be allocated to the Members as provided in Section 1.704-2(i) of the Regulations in accordance with the ratios in which they bear the economic risk of loss under Section 1.752-2 of the Regulations for the Member Nonrecourse Debt to which such partner nonrecourse deductions relate.
Appears in 6 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement (PennyMac Financial Services, Inc.), Limited Liability Company Agreement (ZAIS Group Holdings, Inc.)
Allocation of Partner Nonrecourse Deductions. Any “partner nonrecourse deductions,” Partner Nonrecourse Deductions (within the meaning of Section 1.704-2(i) of the Regulations, ) shall be specially allocated to the Members as provided in Section 1.704-2(i) of the Regulations in accordance with the ratios in which they bear Partner who bears the economic risk of loss under with respect to the Partner Nonrecourse Debt (within the meaning of Section 1.7521.704-2 2(b)(4) of the Regulations for the Member Nonrecourse Debt Regulations) to which such partner nonrecourse deductions relatePartner Nonrecourse Deductions are attributable in accordance with Section 1.704-2(i)(1) of the Regulations.
Appears in 4 contracts
Samples: Limited Partnership Agreement, Limited Partnership Agreement (Parkway Properties Inc), Limited Partnership Agreement (Parkway Properties Inc)
Allocation of Partner Nonrecourse Deductions. Any “partner nonrecourse deductions,” Partner Nonrecourse Deductions (within the meaning of Section 1.704-2(i) of the Regulations, ) shall be specially allocated to the Members as provided in Section 1.704-2(i) of the Regulations in accordance with the ratios in which they bear Member who bears the economic risk of loss under with respect to the Partner Nonrecourse Debt (within the meaning of Section 1.7521.704-2 2(b)(4) of the Regulations for the Member Nonrecourse Debt Regulations) to which such partner nonrecourse deductions relatePartner Nonrecourse Deductions are attributable in accordance with Section 1.704-2(i)(1) of the Regulations.
Appears in 2 contracts
Samples: Limited Liability Company Operating Agreement (Liberty Property Limited Partnership), Limited Liability Company Operating Agreement (Liberty Property Limited Partnership)
