Member Nonrecourse Deductions. Member Nonrecourse Deductions for any Fiscal Year of the Company shall be allocated to the Members in the same proportion as Profits are allocated under Section 2.1.1, provided that any Member Nonrecourse Deductions for any Fiscal Year or other period shall be allocated to the Member who bears (or is deemed to bear) 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)(2).
Appears in 20 contracts
Samples: Operating Agreement (Own Our Own Fund I, LLC), Operating Agreement (Cardone Equity Fund VI, LLC), Operating Agreement (Cardone Equity Fund V, LLC)
Member Nonrecourse Deductions. Member The Members Nonrecourse Deductions for any Fiscal Year fiscal year of the Company shall be allocated to the Members in the same proportion as Profits are allocated under Section 2.1.1, provided that any Member Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated to the Member who that bears (or is deemed to bear) the economic risk of loss with respect to for such deductions within the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation section meaning of Regulations Sections 1.704-2(i)(22(i)(1) and 1.752-2 and otherwise as provided in Regulations Section 1.704-2(i).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Carey Watermark Investors 2 Inc), Limited Liability Company Agreement (Carey Watermark Investors 2 Inc)
Member Nonrecourse Deductions. In accordance with the principles set forth in Regulations Section 1.704-2(i), any Member Nonrecourse Deductions of the Company for any Fiscal Year of the Company Period shall be specially allocated to the Members in accordance with the same proportion as Profits are allocated under Section 2.1.1, provided that any Member Nonrecourse Deductions for any Fiscal Year or other period shall be allocated to the Member who bears (or is deemed to bear) ratios in which they potentially bear 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 the Regulations Section 1.704-2(i)(22(i).
Appears in 2 contracts
Samples: Operating Agreement (FUND.COM Inc.), Operating Agreement (Gerova Financial Group LTD)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any Fiscal Year of the Company shall be specially allocated to among the Members in the same proportion as Profits are allocated under Section 2.1.1, provided that any Member Nonrecourse Deductions for any Fiscal Year or other period shall be allocated to the Member who bears (or is deemed to bear) bear 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)(22(i)(1).
Appears in 1 contract
Samples: Operating Agreement
