Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any 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 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 Treasury Regulation Section 1.704-2(b)(4) and 1.704-2(i).
Appears in 1 contract
Sources: Limited Partnership Agreement (Equity Residential Properties Trust)
Nonrecourse Deductions and Partner Nonrecourse Deductions. Any Nonrecourse Deductions for any Fiscal Year tax year of the Partnership shall be specially allocated to the Partners in accordance with their respective the Partners’ Percentage Interest in Common Partnership Interests. Any , and any Partner Nonrecourse Deductions for any Fiscal Year tax year of the Partnership 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 Treasury Regulation Section Sections 1.704-2(b)(4) and 1.704-2(i).
Appears in 1 contract
Sources: General Partnership Agreement (DPS Americas Beverages Investments, Inc.)