nonrecourse deduction

Antje Matthaeus Oct 28, 2013:

Simpler definition http://www.thefreelibrary.com/Allocations of nonrecourse ded...

Antje Matthaeus Oct 28, 2013:

Abzüge ohne Regress http://books.google.de/books?id=nlLaEDw9IP0C&pg=PA176&lpg=PA...
p. 167

Antje Matthaeus Oct 28, 2013:

Definition Definition of and allocations of nonrecourse deductions. Allocations of losses, deductions, or section 705(a)(2)(B) expenditures attributable to partnership nonrecourse liabilities (“nonrecourse deductions”) cannot have economic effect because the creditor alone bears any economic burden that corresponds to those allocations. Thus, nonrecourse deductions must be allocated in accordance with the partners' interests in the partnership. Paragraph (e) of this section provides a test that deems allocations of nonrecourse deductions to be in accordance with the partners' interests in the partnership. If that test is not satisfied, the partners' distributive shares of nonrecourse deductions are determined under §1.704–1(b)(3), according to the partners' overall economic interests in the partnership. See also paragraph (i) of this section for special rules regarding the allocation of deductions attributable to nonrecourse liabilities for which a partner bears the economic risk of loss (as described in paragraph (b)(4) of this section).
Source: http://www.taxalmanac.org/index.php/Treasury_Regulations,_Su...

Jochen König Oct 27, 2013:

Regresslos mit Diskont / regresslos mit Abschlag Do you have access to this "Reg. Sec. 1-704-2"? It would be helpful to know the client's definition.

I tend to interpret it as "regresslos mit Diskont" as seen in the reference: http://www.lbbw-international.com/imperia/md/content/interna...