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).
Appears in 73 contracts
Samples: Limited Partnership Agreement (Creative Media & Community Trust Corp), Limited Partnership Agreement (Creative Media & Community Trust Corp), Limited Partnership Agreement (Rexford Industrial Realty, Inc.)
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 InterestsInterests in Common-Equivalent 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 Sections 1.704-2(b)(4) and 1.704-2(i).
Appears in 23 contracts
Samples: Limited Partnership Agreement (Digital Realty Trust, L.P.), Agreement of Limited Partnership (Digital Realty Trust, L.P.), Agreement of Limited Partnership (Digital Realty Trust, L.P.)
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Partnership Year shall be specially allocated to the Holders of Partnership Units in accordance with their respective Percentage InterestsPartnership 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).
Appears in 21 contracts
Samples: Limited Partnership Agreement (Hannon Armstrong Sustainable Infrastructure Capital, Inc.), Limited Partnership Agreement (Arbor Realty Trust Inc), Agreement of Limited Partnership (Arbor Realty Trust Inc)
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Partnership Year shall be specially allocated to the Holders Partners in accordance with their respective Percentage Interests. Any Partner Nonrecourse Deductions for any Partnership Year shall be specially allocated to the Holder(sPartner(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 Sections 1.704-2(b)(4) and 1.704-2(i).
Appears in 17 contracts
Samples: Limited Partnership Agreement (Carey Watermark Investors 2 Inc), Limited Partnership Agreement (Hot Springs Cottages Owner, LLC), Limited Partnership Agreement (Omega Healthcare Investors Inc)
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 InterestsInterests with respect to Common 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).
Appears in 9 contracts
Samples: Limited Partnership Agreement (Hudson Pacific Properties, L.P.), Limited Partnership Agreement (Hudson Pacific Properties, L.P.), Agreement of Limited Partnership (Hudson Pacific Properties, L.P.)
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 Sections 1.704-2(b)(4) and 1.704-2(i).
Appears in 5 contracts
Samples: Agreement of Limited Partnership (BioMed Realty Trust Inc), Agreement of Limited Partnership (BioMed Realty Trust Inc), Agreement of Limited Partnership (BioMed Realty Trust Inc)
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 bear(s) 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).
Appears in 4 contracts
Samples: Limited Partnership Agreement (Guide Holdings Inc), Limited Partnership Agreement (Silver Bay Realty Trust Corp.), Limited Partnership Agreement (Silver Bay Realty Trust Corp.)
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Partnership Year shall be specially allocated to the Holders Partners in accordance with their respective Percentage Interests. Any Partner Nonrecourse Deductions for any Partnership Year shall be specially allocated to the Holder(sPartner(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).
Appears in 4 contracts
Samples: Limited Partnership Agreement (Tanger Properties LTD Partnership /Nc/), Limited Partnership Agreement (Tanger Properties LTD Partnership /Nc/), Limited Partnership Agreement (Tanger Properties LTD Partnership /Nc/)
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Partnership Year shall be specially allocated to the Holders of Partnership Common Units in accordance with their respective Percentage InterestsPartnership Common 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(i1.704β2(i).
Appears in 3 contracts
Samples: Limited Partnership Agreement (NorthStar Realty Europe Corp.), Agreement of Limited Partnership (NorthStar Realty Europe Corp.), Limited Partnership Agreement (Northstar Realty Finance Corp.)
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 InterestsInterests with respect to 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).
Appears in 3 contracts
Samples: Limited Partnership Agreement (Ryman Hospitality Properties, Inc.), Second Amended and Restated Agreement of Limited Partnership (Gladstone Commercial Corp), Limited Partnership Agreement (GLADSTONE LAND Corp)
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Partnership Year shall be specially allocated to the Holders of Partnership Units in accordance with their respective Percentage InterestsInterests . 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).
Appears in 2 contracts
Samples: Limited Partnership Agreement (Safety, Income & Growth, Inc.), First Amended and Restated Agreement of Limited Partnership (Safety, Income & Growth, Inc.)
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 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 Sections 1.704-2(b)(4) and 1.704-2(i).
Appears in 2 contracts
Samples: Partnership Agreement (Thomas Properties Group Inc), Limited Partnership Agreement (Thomas Properties Group Inc)
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Partnership Year shall be specially allocated to the Holders of Partnership Common Units in accordance with their respective Percentage InterestsPartnership Common 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).
Appears in 1 contract
Samples: Limited Partnership Agreement (Meruelo Maddux Properties, Inc.)
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Partnership Year shall be specially allocated to the Holders Partners in accordance with their respective Percentage Interests. Any Partner Nonrecourse Deductions for any NY\5888591.8 Partnership Year shall be specially allocated to the Holder(sPartner(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).
Appears in 1 contract
Samples: Limited Partnership Agreement (Tanger Properties LTD Partnership /Nc/)
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 Interestsinterests in the Partnership as determined by the General Partner. 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).
Appears in 1 contract
Samples: Limited Partnership Agreement (MacKenzie Realty Capital, Inc.)
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 InterestsInterests with respect to Common 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 Sections 1.704-2(b)(4) and 1.704-2(i).
Appears in 1 contract
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Partnership Year shall be specially allocated to the Holders Partners in accordance with their respective Junior Percentage Interests. Any Partner Nonrecourse Deductions for any Partnership Year shall be specially allocated to the Holder(s) Partners who bears bear 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).
Appears in 1 contract
Samples: Limited Partnership Agreement (Berkshire Income Realty Inc)
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Partnership Year shall be specially allocated to the Holders of Partnership Common Units in accordance with their respective Percentage InterestsPartnership Common 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 1.704-1.704 2(i).
Appears in 1 contract
Samples: Limited Partnership Agreement (NorthStar Asset Management Group Inc.)
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 Nonre course Debt to which such Partner Nonrecourse Deductions are attributable, in accordance with Regulations Section 1.704-2(i).
Appears in 1 contract
Samples: Limited Partnership Agreement (Westfield America Inc)
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Partnership Year shall be specially allocated to the Holders NY\6167084.9 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).
Appears in 1 contract
Samples: Limited Partnership Agreement (Spirit Realty Capital, Inc.)
