Partner Nonrecourse Liability definition
Examples of Partner Nonrecourse Liability in a sentence
An amount determined by first computing for each Partner Nonrecourse Liability any gain the Company would realize if it disposed of the Company Property subject to that liability for no consideration other than full satisfaction of the liability, and then aggregating the separately computed gains.
Partner Nonrecourse Deductions for any Company fiscal year shall be allocated to the Member who bears the economic risk of loss for the Partner Nonrecourse Liability to which such deductions are attributable, or among all the Members who bear the economic risk of loss for such liability according to the ratio in which they bear such economic risk of loss.
A Partner is not subject to the Partnership Minimum Gain chargeback requirement to the extent their share of the net decrease in Partnership Minimum Gain is caused by a guarantee, refinancing, or other change in the debt instrument causing it to become partially or wholly a recourse liability or a Partner Nonrecourse Liability, and the Partner bears the economic risk of loss (within the meaning of Section 1.752-2 of the Regulations) for the newly guaranteed, refinanced, or otherwise changed liability.
If there is a net decrease in the Partner Nonrecourse Liability Minimum Gain during any period, as determined pursuant to Treasury Regulation § 1.704-2(i), then each Partner shall be allocated items of income and gain in accordance with the provisions of Treasury Regulation § 1.704-2(i).
To the extent the Member contributes capital to the Company that the Company uses to repay the Partner Nonrecourse Liability or to increase the basis of the property subject to the Partner Nonrecourse Liability, and the Member's share of the net decrease in Partner Nonrecourse Debt Minimum Gain results from the repayment or the increase to the property's basis.
Partner Nonrecourse Liability" shall be as defined in Regulation 1.704-2(b)(4).
Any Partner Nonrecourse Deductions for any fiscal year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Partner Nonrecourse Liability to which such Partner Nonrecourse Deductions are attributable in accordance with Treas.
Notwithstanding Section 6.08 hereof, all such nonrecourse deductions attributable to a Partner Nonrecourse Liability must be allocated to the Partner that bears the risk of loss for such Partner Nonrecourse Liability.
If there is a net decrease in the Partner Nonrecourse Liability Minimum Gain (as determined pursuant to applicable Treasury Regulations, including Treasury Regulation Section 1.704-2) during any period, then each Partner shall be allocated items of income and gain in accordance with the provisions of applicable Treasury Regulations, including Treasury Regulation Section 1.704-2.
B.02.1 First, if any portion of a Partnership liability is a Partner Nonrecourse Liability, the Partnership shall allocate Nonrecourse Deductions and Minimum Gain attributable to the Partner Nonrecourse Liability in accordance with Regulation Section 1.704-2(i).