Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Member Nonrecourse Deductions shall be specially allocated to the Members who bear the economic risk of loss with respect to the Member Nonrecourse Debt to which such items are attributable in accordance with Treasury Regulations Section 1.704-2(i).
Appears in 4 contracts
Samples: Series Limited Liability Company Agreement (Tirios Propco Series LLC), Limited Liability Company Agreement (Tirios Propco Series LLC), Series Limited Liability Company Agreement (Emporium Realty Fund I, LLC)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions shall be specially allocated to the Members Member who bear bears the economic risk of loss (within the meaning of Treasury Regulations Section 1.752-2) with respect to the Member Nonrecourse Debt to which such items Member Nonrecourse Deductions are attributable in accordance with and as required by Treasury Regulations Regulation Section 1.704-2(i2(i)(1).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Chardan 2008 China Acquisition Corp.), Limited Liability Company Agreement (DJSP Enterprises, Inc.)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions shall be specially allocated to the Members who bear Member that bears the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such items Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section Regulation (S) 1.704-2(i).
Appears in 2 contracts
Samples: Limited Liability (Inergy L P), Limited Liability Company Agreement (Inergy L P)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreementhereof to the contrary, any Member Nonrecourse Deductions shall be specially allocated to the Members Member who bear bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such items Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i2(i)(1).
Appears in 2 contracts
Samples: Limited Liability Company Operating Agreement (Moody National REIT I, Inc.), Limited Liability Company Operating Agreement (Moody National REIT I, Inc.)
Member Nonrecourse Deductions. Notwithstanding any other provision of anything to the contrary in this Agreement, any Member Nonrecourse Deductions for any taxable year or other period for which allocations are made shall be specially allocated to the Members Member who bear bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such items the Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Cb Richard Ellis Realty Trust), Limited Liability Company Agreement (Cb Richard Ellis Realty Trust)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions shall will be specially allocated to the Members who bear Member that takes the economic risk Economic Risk of loss with respect to Loss for the Member Nonrecourse Debt to which such items are attributable deductions relate as provided in accordance with Treasury Regulations Regulation Section 1.704-2(i2(i)(1).
Appears in 2 contracts
Samples: Operating Agreement (Playboy Enterprises Inc), Operating Agreement (Claxson Interactive Group Inc)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions shall will be specially allocated to the Members who bear Member that bears the economic risk Economic Risk of loss with respect to Loss for the Member Nonrecourse Debt member nonrecourse debt to which such items are attributable deductions relate as provided in accordance with Treasury Regulations Section 1.704-2(i2(i)(1).
Appears in 2 contracts
Samples: Employment Agreement (Simon Worldwide Inc), Employment Agreement (Simon Worldwide Inc)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions Deduction shall be specially allocated to the Members Member who bear bears the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such items Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section Regulation section 1.704-2(i).. (g)
Appears in 2 contracts
Samples: Operating Agreement (First American Capital Corp /Ks), Operating Agreement (First American Capital Corp /Ks)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Member Nonrecourse Deductions shall be specially allocated to the Members Member who bear bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such items are attributable Member Nonrecourse Deductions relate in accordance with Treasury Regulations Section 1.704-2(i).; and
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Plum Creek Timber Co Inc), Limited Liability Company Agreement (MEADWESTVACO Corp)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions shall be specially allocated to the Members Member who bear bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such items Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704l.704-2(i).
Appears in 1 contract
Samples: Operating Agreement (Bespoke Capital Acquisition Corp)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions Deduction shall be specially allocated to the Members Member who bear bears the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such items Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section Regulation § 1.704-2(i).
Appears in 1 contract
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions shall be specially allocated to the Members who which bear the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such items Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section Regulation ss. 1.704-2(i).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Cenex Harvest States Cooperatives)
Member Nonrecourse Deductions. Notwithstanding any other provision of anything to the contrary in this AgreementAgreement (except for Section 9.5), any Member Nonrecourse Deductions for any fiscal year or other period shall be specially specifically allocated to the Members Member who bear bears the economic risk of loss with respect to the Member such Nonrecourse Debt to which such items are attributable in accordance with Treasury Regulations Section 1.704-2(i2(i)(1).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Colonial Properties Trust)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions shall will be specially allocated to the Members who bear Member that bears the economic risk Economic Risk of loss with respect to Loss for the Member Nonrecourse Debt member nonrecourse debt to which such items are attributable deductions relate as provided in accordance with Treasury Regulations Regulation Section 1.704-2(i2(i)(1).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Genius Products Inc)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions Deduction shall be specially allocated to the Members Member who bear bears the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such items Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704ss.1.704-2(i2(i)(1).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Cenex Harvest States Cooperatives)
