Common use of Allocation of Partner Nonrecourse Deductions Clause in Contracts

Allocation of Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any Fiscal Year shall be allocated one hundred percent (100%) to the Member that bears the economic risk of loss (as defined in Regulations Section 1.704-2(b)) with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i). If more than one Member bears the economic risk of loss with respect to a Partner Nonrecourse Debt, the Partner Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such economic risk of loss.

Appears in 7 contracts

Samples: Operating Agreement, Operating Agreement, Operating Agreement

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