Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any fiscal year shall be specially allocated to the Partners in accordance with their Percentage 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 Regulations Sections 1.704-2(b)(4) and 1.704-2(i).
Appears in 4 contracts
Samples: Agreement to Contribute Capital and Escrow Instructions (Arden Realty Inc), Limited Partnership Agreement (Grove Real Estate Asset Trust), Limited Partnership Agreement (Arden Realty Group Inc)
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any fiscal year shall be specially allocated to the Partners in accordance with their Percentage 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 Regulations Sections 1.704-2(b)(4) and Section 1.704-2(i).
Appears in 3 contracts
Samples: Limited Partnership Agreement (Tanger Properties LTD Partnership /Nc/), Limited Partnership Agreement (Tanger Factory Outlet Centers Inc), Agreement of Limited Partnership (Center Trust Inc)
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any fiscal year Fiscal Year shall be specially allocated to the Partners Holders of Partnership Units in accordance with their Percentage InterestsPartnership Units. Any Partner Nonrecourse Deductions for any fiscal year Fiscal Year shall be specially allocated to the Partner(sUnitholder(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 Section 1.704-2(i).
Appears in 3 contracts
Samples: Agreement of Limited Partnership (New Plan Excel Realty Trust Inc), Limited Partnership Agreement (Excel Realty Trust Inc), Agreement of Limited Partnership (Excel Realty Trust Inc)
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any fiscal year shall be specially allocated to the Partners in accordance with their Percentage InterestsInterests attributable to such deductions. 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 Regulations Sections 1.704-1.704- 2(b)(4) and 1.704-2(i).
Appears in 2 contracts
Samples: Agreement of Limited Partnership (Kilroy Realty Corp), Limited Partnership Agreement (Kilroy Realty Corp)
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any fiscal year Fiscal Year shall be specially allocated to the Partners in accordance with their Percentage Interests. Any Partner Nonrecourse Deductions for any fiscal year 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 Regulations Sections 1.704-2(b)(4) and 1.704-2(i).
Appears in 2 contracts
Samples: Contribution Agreement (Thomas Properties Group Inc), Contribution Agreement (Thomas Properties Group Inc)
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any fiscal year shall be specially allocated to the Partners in accordance with their Percentage InterestsInterests attributable to such deductions. 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 Regulations Sections 1.704-2(b)(4) and 1.704-2(i).
Appears in 2 contracts
Samples: Limited Partnership Agreement (National Golf Properties Inc), Agreement of Limited Partnership (National Golf Properties Inc)
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any fiscal year 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 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 Regulations Sections Treasury Regulation Section 1.704-2(b)(4) and 1.704-2(i).
Appears in 1 contract
Samples: Limited Partnership Agreement (Equity Residential Properties Trust)
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any fiscal year Fiscal Year or other period shall be specially allocated among the Members in proportion to the Partners in accordance with their respective Percentage Interests. Any Partner Nonrecourse Deductions for any fiscal year Fiscal Year shall be specially allocated to the Partner(s) Member who bears the economic risk of loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable, attributable in accordance with Regulations Sections § 1.704-2(b)(4) and 1.704-2(i2(i)(1).
Appears in 1 contract
Samples: Limited Liability Company Agreement
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any fiscal year Fiscal Year shall be specially allocated to the Partners in accordance with their Percentage Interests. Any Partner Nonrecourse Deductions for any fiscal year Fiscal Year shall be specially allocated to the Partner(s) who bears bear(s) the economic risk of loss (within the meaning of Treasury Regulations Section 1.752-2) with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable, in accordance with Treasury Regulations Sections 1.704-2(b)(4) and Section 1.704-2(i).
Appears in 1 contract
Samples: Limited Partnership Agreement (Hudson Pacific Properties, Inc.)
