Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated 100% to the Member that bears the Economic Risk of Loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section 1.704-2(i). If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk of Loss.
Appears in 37 contracts
Samples: Operating Agreement (Atlas Energy Resources, LLC), Limited Liability Company Agreement (Copano Energy, L.L.C.), Limited Liability Company Agreement (Vanguard Natural Resources, LLC)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated 100% to the Member that bears the “Economic Risk of Loss Loss” (as defined in the Treasury Regulations) with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Regulations Section 1.704-2(i). If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk of Loss.
Appears in 33 contracts
Samples: Limited Liability Company Agreement (NRG Yield, Inc.), Limited Liability Company Agreement (TerraForm Power, Inc.), Limited Liability Company Agreement (DynaVox Inc.)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period year shall be allocated 100% to the Member that bears the Economic Risk of Loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section 1.704-2(i). If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk of Loss. This Section 9.2(b) is intended to comply with the provisions of Treasury Regulation Section 1.704-2(i) and shall be interpreted consistently therewith.
Appears in 5 contracts
Samples: Limited Liability Company Agreement (Markwest Energy Partners L P), Limited Liability Company Agreement (Markwest Energy Partners L P), Limited Liability Company Agreement (Markwest Energy Partners L P)
Member Nonrecourse Deductions. The Member Nonrecourse Deductions for any taxable period year shall be allocated 100% to the Member that bears the Economic Risk economic risk of Loss with respect to loss (within the meaning of Regulations § 1.752-2) for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section Regulations § 1.704-2(i). If more than one Member bears the Economic Risk economic risk of Loss loss with respect to a Member Nonrecourse Debt, such the Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk economic risk of Lossloss.
Appears in 5 contracts
Samples: Limited Liability Company Agreement (Paulsboro Natural Gas Pipeline Co LLC), Support Agreement (Sunoco LP), Operating Agreement (Sunoco LP)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated 100% to the Member that bears the Economic Risk economic risk of Loss loss (as described in Regulations Section 1.704-2(b) with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Regulations Section 1.704-2(i)). If more than one Member bears the Economic Risk economic risk of Loss loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk economic risk of Lossloss.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Energy Transfer Partners, L.P.), Redemption Agreement (Energy Transfer Equity, L.P.), Limited Liability Company Agreement (Southern Union Co)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period Fiscal Year shall be allocated one hundred percent (100% %) to the Member that bears the Economic Risk of Loss with respect to the such Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section section 1.704-2(i). If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk of Loss.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Vine Energy Inc.), Limited Liability Company Agreement (Vine Energy Inc.), Limited Liability Company Agreement (Vine Resources Inc.)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated 100% to the Member that bears the Economic Risk of Loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section 1.704-2(i)) of the Regulations. If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk of Loss.
Appears in 4 contracts
Samples: Operating Agreement (RCN Corp /De/), Operating Agreement (RCN Corp /De/), Operating Agreement (Nstar/Ma)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions of the Company for any taxable period shall be allocated one hundred percent (100% %) to the Member that bears the Economic Risk of Loss with respect to the for such Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Regulations Section 1.704-2(i). If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk of Loss.
Appears in 4 contracts
Samples: Operating Agreement (Pebblebrook Hotel Trust), Operating Agreement (Pebblebrook Hotel Trust), Operating Agreement (Pebblebrook Hotel Trust)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period year shall be allocated 100% to the Member that bears the Economic Risk of Loss with respect to the for such Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section section 1.704-2(i) (or any successor provision). If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members ratably in accordance with the ratios in which they share proportion to their respective shares of such Economic Risk of Loss.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Williams Partners L.P.), Limited Liability Company Agreement (Williams Partners L.P.), Limited Liability Company (Williams Partners L.P.)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated 100% to the Member that bears the Economic Risk of Loss with respect to the for such Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section section 1.704-2(i) (or any successor provision). If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members ratably in accordance with the ratios in which they share proportion to their respective shares of such Economic Risk of Loss.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (El Paso Energy Partners Lp), Limited Liability Company Agreement (El Paso Energy Partners Lp), El Paso Energy Partners Lp
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated 100% to the Member that bears the Economic Risk of Loss with respect to the such Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section section 1.704-2(i). If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk of Loss.
Appears in 3 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement (Crestwood Midstream Partners LP), Limited Liability Company Agreement (Inergy Storage, Inc.)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated 100% to the Member that bears the Economic Risk economic risk of Loss loss (as defined in Treasury Regulations Section 1.704-2(b) with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Regulations Section 1.704-2(i)). If more than one Member bears the Economic Risk economic risk of Loss loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk economic risk of Lossloss.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Regency Centers Corp), Limited Liability Company Agreement (Regency Centers Lp), Operating Agreement (Burnham Pacific Properties Inc)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period year shall be allocated 100% to the Member that bears the Economic Risk of Loss with respect to the for such Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Regulations Section 1.704-2(i) (or any successor provision). If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members ratably in accordance with the ratios in which they share proportion to their respective shares of such Economic Risk of Loss.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Atlas Pipeline Holdings, L.P.), Limited Liability Company Agreement (Atlas Pipeline Partners Lp)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated one hundred percent (100% %) to the Member that bears the Economic Risk economic risk of Loss loss (as defined in Treasury Regulations Section 1.704-2(b) with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Regulations Section 1.704-2(i)). If more than one Member bears the Economic Risk economic risk of Loss loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk economic risk of Lossloss.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (MPG Office Trust, Inc.), Limited Liability Company Agreement (Maguire Properties Inc)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period Fiscal Year shall be allocated one hundred percent (100% %) to the Member that bears the Economic Risk economic risk of Loss loss (as defined in Regulations Section 1.704-2(b)) with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Regulations Section 1.704-2(i). If more than one Member bears the Economic Risk economic risk of Loss loss with respect to a Member Nonrecourse Debt, such the Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk economic risk of Lossloss.
Appears in 2 contracts
Samples: Limited Liability Company Operating Agreement (Shipyard River Coal Terminal Co), Limited Liability (Shipyard River Coal Terminal Co)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period Fiscal Year shall be allocated one hundred percent (100% %) to the Member that bears the Economic Risk of Loss with respect to the such Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section 1.704section 1,704-2(i). If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk of Loss.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (SilverSun Technologies, Inc.), Limited Liability Company Agreement (SilverSun Technologies, Inc.)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period year shall be allocated 100% to the Member that bears the Economic Risk of Loss with respect to the for such Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section Regulations section 1.704-2(i) (or any successor provision). If more than one Member bears the Economic Risk of Loss with of respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members ratably in accordance with the ratios in which they share proportion to their respective shares of such Economic Risk of Loss.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (DCP Midstream Partners, LP), Limited Liability Company Agreement (DCP Midstream Partners, LP)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions of the Company for any taxable period shall be allocated one hundred percent (100% %) to the Member that bears the Economic Risk of Loss with respect to the for such Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Regulations Section 1.704-2(i1.704‑2(i). If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk of Loss.
Appears in 2 contracts
Samples: Operating Agreement (Hersha Hospitality Trust), Operating Agreement (Hersha Hospitality Trust)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period Fiscal Year shall be allocated one hundred percent (100% %) to the Member that bears the Economic Risk of Loss with respect to the such Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section section 1.704-2(i). If more than one (1) Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk of Loss.
Appears in 2 contracts
Samples: Production Marketing Agreement (Sanchez Energy Corp), Limited Liability Company Agreement (Sanchez Energy Corp)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated 100% to the Member that bears the Economic Risk of Loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section 1.704-2(i). If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such the Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members Member in accordance with the ratios in which they share such Economic Risk of Loss.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Sunpower Corp), Limited Liability Company Agreement (8point3 Energy Partners LP)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall will be allocated 100% to the Member that bears the Economic Risk of Loss with respect to regarding the Member Nonrecourse Debt to which such the Member Nonrecourse Deductions are attributable in accordance with under Treasury Regulation Section 1.704-2(i). If more than one Member bears the Economic Risk of Loss with respect to regarding a Member Nonrecourse Debt, such the Member Nonrecourse Deductions attributable thereto shall will be allocated between or among such the Members in accordance with under the ratios in which they share such the Economic Risk of Loss.
Appears in 1 contract
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period Fiscal Year shall be allocated 100% to the Member that bears the Economic Risk economic risk of Loss loss (within the meaning of Regulations Section 1.752-2) with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Regulations Section 1.704-2(i). If more than one Member bears the Economic Risk economic risk of Loss loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk economic risk of Lossloss.
Appears in 1 contract
Samples: Limited Liability Company Agreement (NextDecade Corp.)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated 100% to the Member that bears the Economic Risk economic risk of Loss loss (as defined in Regulations Section 1.704-2(b) with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Regulations Section 1.704-2(i)). If more than one Member bears the Economic Risk economic risk of Loss loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk economic risk of Lossloss.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Empire Resorts Inc)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period Allocation Period shall be allocated one hundred percent (100% %) to the Member that bears the Economic Risk of Loss with respect to the such Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section section 1.704-2(i). If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk of Loss.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Delek US Holdings, Inc.)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated 100% to the Member that bears the Economic Risk economic risk of Loss loss (as defined in Treasury Regulations Section 1.704-2(b)) with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Regulations Section 1.704-2(i). If more than one Member bears the Economic Risk economic risk of Loss loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk economic risk of Loss.loss. g)
Appears in 1 contract
Samples: Limited Liability Company Operating Agreement (Starboard Resources, Inc.)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any such taxable period shall be allocated 100% to the Member that bears the Economic Risk of Loss with respect to the for such Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section section 1.704-2(i) (or any successor provision). If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members ratably in accordance with the ratios in which they share proportion to their respective shares of such Economic Risk of Loss.
Appears in 1 contract
Samples: Limited Liability Company Agreement (El Paso Energy Partners Lp)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated 100% to the Member that bears the Economic Risk of Loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section 1.704-2(i)) of the Treasury Regulations. If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk of Loss.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Translink Management Development Corp)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period Tax Period shall be allocated 100% 100 percent to the Member that bears the Economic Risk of Loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section 1.704Treas. Reg. ss.1.704-2(i). If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk of Loss.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Quest Resource Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable period Fiscal Period shall be specially allocated 100% to the Member that bears or Members who bear the Economic Risk economic risk of Loss loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable attributable, as determined in accordance with Treasury Regulation Regulations Section 1.704-2(i)2(0. If more than one Member bears the Economic Risk economic risk of Loss loss with respect to a Member Nonrecourse Debt, any Member Nonrecourse Deductions with respect to such Member Nonrecourse Deductions attributable thereto Debt shall be specially allocated between or among such Members in accordance with the ratios in which they the Members share the economic risk of loss for such Economic Risk of LossMember Nonrecourse Debt.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Javo Beverage Co Inc)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period Taxable Period shall be allocated 100% to the Member that bears the Economic Risk of Loss with respect to for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section 1.704-2(i). If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such the Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk of Loss.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Tallgrass Energy Partners, LP)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated one hundred percent (100% %) to the Member that bears the Economic Risk of Loss with respect to the such Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section section 1.704-2(i). If more than one Member bears both Members bear the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such the Members in accordance with the ratios in which they share such Economic Risk of Loss.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Regency Energy Partners LP)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated 100% to the Member that bears the Economic Risk economic risk of Loss loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Regulations Section 1.704-2(i)). If more than one Member bears the Economic Risk economic risk of Loss loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk economic risk of Lossloss.
Appears in 1 contract
Samples: Limited Liability Company Agreement (CBL & Associates Limited Partnership)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated one hundred percent (100% %) to the Member that bears the Economic Risk of Loss with respect to for the Member Company’s Nonrecourse Debt Liability to which such Member Member’s Nonrecourse Deductions are attributable in accordance with Treasury Regulation Regulations Section 1.704-2(i). If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk of Loss.
Appears in 1 contract
Samples: Limited Liability Company Agreement (TransMontaigne Partners L.P.)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated 100% to the Trinity Member that bears the Economic Risk of Loss with respect to the such Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section section 1.704-2(i). If more than one Trinity Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Trinity Members in accordance with the ratios in which they share such Economic Risk of Loss.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Anadarko Petroleum Corp)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated 100% entirely to the Member Members that bears the Economic Risk of Loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section 1.704-2(i). If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk of Loss.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Teppco Partners Lp)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated one hundred percent (100% %) to the Member that bears the Economic Risk economic risk of Loss loss (as defined in Treasury Regulations Section 1.704-2(b) with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Regulations Section 1.704-2(i)). If more than one Member bears the Economic Risk economic risk of Loss loss with respect to a Member Nonrecourse Nonrecoune Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk economic risk of Lossloss.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Maguire Properties Inc)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated 100% to the Member that bears the Economic Risk of Loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section 1.704-2(i). If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios manner in which they share such Economic Risk of Loss.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Eott Energy LLC)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated 100% to the Member that bears the Economic Risk of Loss with respect to the Member for such Company Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury IRS Regulation Section 1.704-2(i). If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk of Loss.
Appears in 1 contract
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period year shall be allocated one hundred percent (100% %) to the Member that bears the Economic Risk of Loss with respect to the for such Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section section 1.704-2(i) (or any successor provision). If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members ratably in accordance with the ratios in which they share proportion to their respective shares of such Economic Risk of Loss.
Appears in 1 contract
Samples: Limited Liability Company Agreement (ONEOK Partners LP)
