Common use of AND PARTNER NONRECOURSE DEBT Clause in Contracts

AND PARTNER NONRECOURSE DEBT. Notwithstanding the foregoing, (i) in the event Code Section 704(c) or Code Section 704(c) principles applicable under Regulations Section 1.704-1(b)(2)(iv) require allocations of income or loss of the Partnership in a manner different than that set forth above, the provisions of Section 704(c) and the Regulations thereunder shall control such allocations among the Partners; and (ii) all tax deductions and taxable losses of the Partnership that, pursuant to Regulations Section 1.704-2(i), are attributable to a Partner Nonrecourse Debt for which a Partner (or a Person related to such Partner under Treasury Regulations Section 1.752-4(b)) bears the economic risk of loss (within the meaning of Regulations Section 1.752-2) shall be allocated to such Partner as required by Regulations Section 1.704-2(c).

AND PARTNER NONRECOURSE DEBT. Notwithstanding the foregoing, (i) in the event Code Section 704(c) or Code Section 704(c) principles applicable under Regulations Section 1.704-1(b)(2)(iv) require allocations of income or loss of the Partnership in a manner different than that set forth above, the provisions of Section 704(c) and the Regulations thereunder shall control such allocations among the Partners; and (ii) all tax deductions and taxable losses of the Partnership that, pursuant to Regulations Section 1.704-2(i1(i), are attributable to a Partner Nonrecourse Debt for which a Partner (or a Person related to such Partner under Treasury Regulations Section 1.752-4(b)) bears the economic risk of loss (within the meaning of Regulations Section 1.752-2) shall be allocated to such Partner as required by Regulations Section 1.704-2(c).