Unit Holder Nonrecourse Deductions Sample Clauses
The Unit Holder Nonrecourse Deductions clause defines how tax deductions related to nonrecourse liabilities are allocated among unit holders in a partnership or similar entity. In practice, this clause specifies that deductions arising from debts for which no partner is personally liable are distributed to unit holders according to their ownership interests or as outlined in the agreement. This ensures that tax benefits from nonrecourse financing are fairly and transparently allocated, preventing disputes and aligning with tax regulations.
Unit Holder Nonrecourse Deductions. Any Unit Holder Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Unit Holder who bears the economic risk of loss with respect to the Unit Holder Nonrecourse Debt to which such Unit Holder Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1).
Unit Holder Nonrecourse Deductions. Any Unit Holder Nonrecourse Deduction for any taxable year or other period shall be specially allocated to the Unit Holder who bears the risk of loss with respect to the Unit Holder Nonrecourse Liability to which the Unit Holder Nonrecourse Deduction is attributable, as determined in accordance with Regulation Section 1.704-2(b).