Allocation of Excess Nonrecourse Liabilities. Excess nonrecourse liabilities" of the Fund as used in Section 1.752-3(a)(3) of the Treasury Regulations will first be allocated among the Member pursuant to the "additional method" described in that section and then in accordance with the manner in which the Manager expects the nonrecourse deductions allocable to those liabilities will be allocated.
Appears in 7 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement, Limited Liability Company Agreement
Allocation of Excess Nonrecourse Liabilities. “Excess nonrecourse liabilities" ” of the Fund Company as used in Section 1.752-3(a)(3) of the Treasury Regulations will shall first be allocated among the Member pursuant to the "“additional method" ” described in that such section and then in accordance with the manner in which the Manager expects the nonrecourse deductions allocable to those such liabilities will be allocated.allocated.
Appears in 2 contracts
Samples: Limited Liability Company Operating Agreement, Limited Liability Company Operating Agreement
Allocation of Excess Nonrecourse Liabilities. “Excess nonrecourse liabilities" ” of the Fund Company as used in Section 1.752-3(a)(3) of the Treasury Regulations will first be allocated among the Member pursuant to the "“additional method" ” described in that section and then in accordance with the manner in which the Manager expects the nonrecourse deductions allocable to those liabilities will be allocated.
Appears in 1 contract
Samples: Company Agreement
Allocation of Excess Nonrecourse Liabilities. “Excess nonrecourse liabilities" ” of the Fund Company as used in Section 1.752-3(a)(3) of the Treasury Regulations will shall first be allocated among the Member pursuant to the "“additional method" ” described in that such section and then in accordance with the manner in which the Manager expects the nonrecourse deductions allocable to those such liabilities will be allocated.
Appears in 1 contract
