Partner Non-Recourse Deductions. Any partner non-recourse deductions (as defined in Regulations Section 1.704-2(i)(1)) for any taxable year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the partner non-recourse debt to which such partner non-recourse deductions are attributable in accordance with Regulations Section 1.704-2(i). The amount of partner non-recourse deductions shall be determined in accordance with Regulations Section 1.704-2(i)(2).
Appears in 3 contracts
Samples: Transaction Agreement (Nord Anglia Education, Inc.), Limited Liability Company Agreement, Transaction Agreement (Nord Anglia Education, Inc.)
Partner Non-Recourse Deductions. Any partner non-recourse deductions (as defined in Regulations Section 1.704-2(i)(1)) for any taxable year or other period shall be specially allocated to the Member Partner who bears the economic risk of loss with respect to the partner non-recourse debt to which such partner non-recourse deductions are attributable in accordance with Regulations Section 1.704-2(i). The amount of partner non-recourse deductions shall be determined in accordance with Regulations Section 1.704-2(i)(2).
Appears in 3 contracts
Samples: Subscription and Support Agreement (Blue Eagle Holdings, L.P.), Subscription and Support Agreement (Blue Eagle Holdings, L.P.), Contribution and Support Agreement (Innotrac Corp)
