Member Nonrecourse Deductions. Those items of Company loss, deduction or Code Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to Treasury Regulations Section 1.704-2(i).
Appears in 38 contracts
Samples: Operating Agreement, Operating Agreement, Operating Agreement
Member Nonrecourse Deductions. Those items of Company loss, deduction deduction, or Code Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to Treasury which such items are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 8 contracts
Samples: Operating Agreement (Osi Restaurant Partners, LLC), Operating Agreement (Osi Restaurant Partners, LLC), Operating Agreement (Bloomin' Brands, Inc.)
Member Nonrecourse Deductions. Those Notwithstanding Section 8.3.2, those items of Company loss, deduction deduction, or Code Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt nonrecourse debt for any fiscal year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according nonrecourse debt to which such items are attributable in accordance with Treasury Regulations Section 1.704-2(i).
Appears in 7 contracts
Samples: Membership Interest Purchase Agreement (Nutracea), Limited Liability Company Agreement (Nutracea), Limited Liability Company Agreement (Nutracea)
Member Nonrecourse Deductions. Those items Items of Company the Company’s loss, deduction or Code deductions, and expenditures described in Section 705(a)(2)(B) expenditures which of the Code that are attributable to the Company’s nonrecourse debt and are characterized as Member Nonrecourse Debt shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to Treasury Regulations nonrecourse deductions under Section 1.704-2(i)) of the Regulations will be allocated to the Members’ Capital Accounts in accordance with Section 1.704-2(i) of the Regulations.
Appears in 7 contracts
Samples: Operating Agreement (Slingshot USA LLC), Operating Agreement, Operating Agreement (Slingshot USA LLC)
Member Nonrecourse Deductions. Those Notwithstanding Section 6.1, those items of Company loss, deduction deduction, or Code Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to Treasury which such items are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 4 contracts
Samples: Index Operating Agreement, Operating Agreement (Atwood Minerals & Mining CORP.), Operating Agreement (Atwood Minerals & Mining CORP.)
Member Nonrecourse Deductions. Those items of Company loss, deduction deduction, or Code Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt for any Fiscal Year or other period shall be specially allocated to the Member who bears bear the economic risk of loss with respect to the Member Nonrecourse Debt according to Treasury which such items are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 4 contracts
Samples: Revised And (Dover Investments Corp), Operating Agreement (Dover Investments Corp), Operating Agreement (Dover Investments Corp)
Member Nonrecourse Deductions. Those items of Company loss, deduction ----------------------------- deduction, or Code Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to Treasury which such items are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 3 contracts
Samples: Operating Agreement (Franchise Mortgage Acceptance Co), Operating Agreement (Auto Marketing Network Inc), First American Financial Corp
Member Nonrecourse Deductions. Those Notwithstanding Section 6.1 above, those items of Company LLC loss, deduction or Code Section IRC § 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to Treasury Regulations Section which such items are attributable in accordance with Regs § 1.704-2(i).
Appears in 2 contracts
Samples: Operating Agreement (Molecular Imaging Corp), Operating Agreement (Molecular Imaging Corp)
Member Nonrecourse Deductions. Those items of Company loss, deduction deduction, or Code Section 705(a)(2)(B) expenditures which that are attributable to Member Nonrecourse Debt for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to Treasury which such items are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 2 contracts
Samples: Guaranty Agreement, Guaranty Agreement (NRG Yield, Inc.)
Member Nonrecourse Deductions. Those items of Company loss, deduction or Code Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt for any fiscal year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to which such items are attributable in accordance with Treasury Regulations Section 1.704-2(i2(I).
Appears in 2 contracts
Samples: Operating Agreement (World Heart Corp), Operating Agreement (Response Usa Inc)
Member Nonrecourse Deductions. Those any and all items of Company loss, deduction or Code expenditure (including, without limitation, any expenditure described in Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt shall be specially allocated to of the Member who bears Code) that, in accordance with the economic risk principles of loss with respect to the Member Nonrecourse Debt according to Treasury Regulations Regulation Section 1.704-2(i), are attributable to a Member Nonrecourse Debt.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Enterprise Products Partners L P), Limited Liability Company Agreement (Enterprise Products Partners L P)
Member Nonrecourse Deductions. Those Notwithstanding Section 6.1, those items of Company loss, deduction deduction, or Code Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according debt to Treasury which such items are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Imperial Capital Group, Inc.), Limited Liability Company Agreement (Imperial Capital Group, Inc.)
Member Nonrecourse Deductions. Those Notwithstanding Section ------------------------------ 6.1, those items of Company loss, deduction deduction, or Code Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to Treasury which such items are attributable in accordance with Regulations Section 1.704l.704-2(i).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Point West Capital Corp), Limited Liability Company Agreement (Point West Capital Corp)
Member Nonrecourse Deductions. Those items of Company loss, deduction deduction, or Code Section 705(a)(2)(B705 (a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to Treasury which such items are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 2 contracts
Samples: Operating Agreement (Dover Investments Corp), Dover Investments Corp
Member Nonrecourse Deductions. Those items of Company loss, deduction deduction, or Code Section 705(a)(2)(B705(a) (2) (B) expenditures which are attributable to Member Nonrecourse Debt for any fiscal year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to which such items are attributable in accordance with Treasury Regulations Section 1.704-2(i2(I).
Appears in 1 contract
Samples: Operating Agreement
Member Nonrecourse Deductions. Those items of Company loss, deduction deduction, or Code Section § 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to Treasury which such items are attributable in accordance with Regulations Section § 1.704-2(i).
Appears in 1 contract
Member Nonrecourse Deductions. Those items Items of Company loss, deduction deduction, or Code Section 705(a)(2)(B) expenditures which expenditure that are attributable to a Member Nonrecourse Debt Liability (“Member Nonrecourse Deductions”) shall be specially allocated to the Member who bears Members in the economic risk ratio in which they share the Economic Risk of loss Loss with respect to such liability within the Member Nonrecourse Debt according to Treasury Regulations meaning of Treas. Reg. Section 1.704-2(i)1.
Appears in 1 contract
Samples: Limited Liability Company Operating Agreement (Comstock Holding Companies, Inc.)
Member Nonrecourse Deductions. Those Notwithstanding Section 6.4, those items of Company loss, deduction deduction, or Code Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt for any Membership Class for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to Treasury which such items are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 1 contract
Samples: Limited Liability Company Agreement
Member Nonrecourse Deductions. Those items of Company loss, deduction deduction, or Code Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to which such items are attributable in accordance with Treasury Regulations Section 1.704-2(i).
Appears in 1 contract
Samples: Limited Liability Company Agreement
Member Nonrecourse Deductions. Those items of Company loss, deduction ----------------------------- deduction, or Code Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt for any fiscal year or other period shall be specially specifically allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to which such items are attributable in accordance with Treasury Regulations Section 1.704-2(i).
Appears in 1 contract
Member Nonrecourse Deductions. Those items of Company loss, deduction deduction, or Code Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt for any fiscal year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to which such items are attributable in accordance with Treasury Regulations Section 1.704-2(i).
Appears in 1 contract
Samples: Operating Agreement (Kw 2012 C, LLC)
Member Nonrecourse Deductions. Those Notwithstanding Section 6.1, those ----------------------------- items of Company loss, deduction deduction, or Code Section 705(a)(2)(B) expenditures which are attributable to a particular Member Nonrecourse Debt for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to Treasury which such items are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 1 contract
Member Nonrecourse Deductions. Those items of Company lossLoss, deduction deduction, or Code Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt for any fiscal year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to which such items are attributable in accordance with Treasury Regulations Section 1.704-2(i).
Appears in 1 contract
Samples: Operating Agreement (Ckrush, Inc.)
Member Nonrecourse Deductions. Those items Items of Company loss, deduction deduction, or Code Section 705(a)(2)(B) expenditures which expenditure that are attributable to a Member Nonrecourse Debt Liability (“Member Nonrecourse Deductions”) shall be specially allocated to the Member who bears Members in the economic risk ratio in which they share the Economic Risk of loss Loss with respect to such liability within the Member Nonrecourse Debt according meaning of Treas. Reg. Section 1.752-2. This provision is to Treasury Regulations be interpreted in a manner consistent with the requirements of Treas. Reg. Section 1.704-2(i1.704‑2(i).
Appears in 1 contract
Samples: Operating Agreement (Comstock Holding Companies, Inc.)
Member Nonrecourse Deductions. Those items of Company loss, deduction deduction, or Code Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt for any fiscal year or other period shall be specially specifically allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to which such items are attributable in accordance with Treasury Regulations Section 1.704-2(i).
Appears in 1 contract
Member Nonrecourse Deductions. Those items Items of Company loss, deduction or Code and expenditures described in Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt shall be specially allocated to any nonrecourse debt of the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to Treasury Regulations Company and are characterized as partner (Member) nonrecourse deductions under Section 1.704-2(i)) of the Treasury Regulations shall be allocated to the Equity Owners’ Capital Accounts in accordance with said Section 1.704-2(i) of the Treasury Regulations.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Phoenix Capital Group Holdings, LLC)
Member Nonrecourse Deductions. Those Notwithstanding Section 7.1, those items of Company loss, deduction deduction, or Code Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to which such items are attributable in accordance with Treasury Regulations Section 1.704-2(i).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Versity Invest, LLC)
Member Nonrecourse Deductions. Those items of Company loss, deduction deduction, or Code Section 705(a)(2)(B) expenditures which that are attributable to Member Nonrecourse Debt for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to Treasury which such items are attributable in accordance with Regulations Section §1.704-2(i).
Appears in 1 contract
Samples: Operating Agreement (Red Rock Pictures Holdings, Inc)
Member Nonrecourse Deductions. Those items of Company loss, deduction deduction, or Code Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to Treasury which such items are attributable in accordance with Regulations Section Sections 1.704-2(b)(4) and 1.704-2(i).
Appears in 1 contract
Member Nonrecourse Deductions. Those Notwithstanding Section 6.1, those items of Company loss, deduction deduction, or Code Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt shall for any Fiscal Year or other period will be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to Treasury which such items are attributable in accordance with Regulations Section 1.704-2(i).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Provision Holding, Inc.)
Member Nonrecourse Deductions. Those items of Company loss, deduction deduction, or Code Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt for any Fiscal Year or other period shall be specially allocated to the Member or Economic Interest Owner who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to which such items are attributable in accordance with Treasury Regulations Section 1.704-2(i).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Solar Power, Inc.)
Member Nonrecourse Deductions. Those items of Company loss, deduction deduction, or Code Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to Treasury which such items are attributable in accordance with Regulations Section § 1.704-2(i).
Appears in 1 contract
