Non-Recourse Deductions definition

Non-Recourse Deductions has the meaning set forth in Treasury Regulation Section 1.704-2(b)(1).

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Non-Recourse Deductions shall have the meaning, and the amount thereof shall be, as set forth in Treasury Regulations Section 1.704-2(c).

Non-Recourse Deductions means any and all items of loss, deduction or expenditure (including any expenditure described in Section 705(a)(2)(B) of the Code), Simulated Depletion or Simulated Loss that, in accordance with the principles of Treasury Regulation Section 1.704-2(b), are attributable to a Non-Recourse Liability.

Examples of Non-Recourse Deductions in a sentence

Non-Recourse Deductions for any Fiscal Year shall be allocated to the Members in accordance with their Percentage Interests.
If more than one Partner bears the Economic Risk of Loss with respect to a Partner Non-Recourse Debt, such Partner Non-Recourse Deductions attributable thereto shall be allocated between or among such Partners in accordance with the ratios in which they share such Economic Risk of Loss.
Partner Non-Recourse Deductions for any taxable period shall be allocated 100% to the Partner that 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 Treasury Regulation Section 1.704-2(i).
If the General Partner determines that the Partnership’s Non-Recourse Deductions should be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Non-Recourse Deductions for any Fiscal Year or other period shall be allocated 99% to the Members in proportion to their Units and 1% to the Managers and each Member’s and the Manager’s share of Excess Non-recourse Liabilities shall be in the same proportion.

More Definitions of Non-Recourse Deductions

Non-Recourse Deductions. Refers to section 705(a)(2)(B) (of the Code) expenditures attributable to partnership nonrecourse liabilities.

Non-Recourse Deductions for a taxable year means deductions attributable to non-recourse debt (as determined under Treasury Regulation Sections 1.704-2(c) and 1.704-2(i)(2)) for such year.

Non-Recourse Deductions as defined in Regulations Section 1.704-2(c) for any fiscal year or other period shall be specially allocated as items of loss in the manner provided in Regulations Section 1.704-2(j)(1)(ii).

Non-Recourse Deductions shall have the meaning set forth in Section 1.704-2(b)(1) and (c) of the Regulations.

Non-Recourse Deductions shall have the meaning set forth in Treasury Regulations Section 1.704-2(b)(1); “Partner Non-recourse deductions” shall have the meaning set forth in Treasury Regulations Section 1.704-2(i)(1); and “Partner Non-recourse Debt” shall have the meaning set forth in Treasury Regulations Section 1.704-2(b)(4).

Non-Recourse Deductions has the meaning set forth in Section 5.4(b).

Non-Recourse Deductions means the excess, if any, of the net increase in the amount of Minimum Gain during a partnership's taxable year, over the aggregate amount of any distributions during such year of proceeds of non-recourse liability that are allocable to an increase in Minimum Gain. Section 1.704-1T(b)(4)(iv)(b) of the Regulations. The Non-recourse Deductions of the Partnership for a taxable year shall consist first of depreciation or cost recovery deductions with respect to items of Partnership property or other assets to the extent of the increase in Minimum Gain attributable to any Non-recourse Debt of the Partnership secured by such Partnership property or assets and, to the extent necessary, a pro rata portion of the Partnership's other items of loss, deduction and non-deductible expenditures under Section 705(a)(2)(B) of the Code (to the extent such non-deductible expenditures reduce Capital Accounts). Non-recourse Deductions shall be determined in accordance with the rules in Section 1.704-1T(b)(4)(iv) of the Regulations, and any subsequent rule or regulation governing the determination of Non-recourse Deductions.