Partner Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1).
Appears in 6 contracts
Samples: Limited Liability Company Agreement (MGM Resorts International), Limited Liability Company Agreement (MGM Resorts International), Limited Liability Company Agreement (CityCenter Holdings, LLC)
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse Deductions for any Fiscal Year Period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Partner Nonrecourse Debt to which such Member Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i)(1)2.
Appears in 5 contracts
Samples: Limited Liability Company Operating Agreement (Excelsior Venture Partners Iii LLC), Limited Liability Company Operating Agreement (Excelsior Venture Partners Iii LLC), Limited Liability Company Operating Agreement (Excelsior Venture Partners Iii LLC)
Partner Nonrecourse Deductions. Any Member Nonrecourse Deductions partner nonrecourse deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt partner nonrecourse debt to which such Member Nonrecourse Deductions partner nonrecourse deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i)(1).
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Chatham Lodging Trust), Limited Liability Company Agreement (Chatham Lodging Trust), Limited Liability Company Agreement (Chatham Lodging Trust)
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Partner Nonrecourse Debt to which such Member Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1)) of the Tax Regulations.
Appears in 4 contracts
Samples: Limited Liability Company Operating Agreement, Operating Agreement (Mack Cali Realty L P), Operating Agreement (Mack Cali Realty Corp)
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Partner Nonrecourse Debt to which such Member Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1).
Appears in 3 contracts
Samples: Limited Liability Company Operating Agreement (Diamond Resorts Parent, LLC), Limited Liability Company Operating Agreement (Diamond Resorts Parent, LLC), Limited Liability Company Agreement (Diamond Resorts Parent, LLC)
Partner Nonrecourse Deductions. Any Member Nonrecourse Deductions Partner nonrecourse deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss loss, or to the Members in the proportions in which they bear the economic risk of loss, with respect to the Member Nonrecourse Debt partner nonrecourse debt to which such Member Nonrecourse Deductions partner nonrecourse deductions are attributable in accordance with Regulations Section 1.704-2(i)(1)) of the Regulations.
Appears in 3 contracts
Samples: Operating Agreement (Amyris, Inc.), Operating Agreement (Amyris, Inc.), Operating Agreement (Digital Cinema Destinations Corp.)
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss loss, or to the Members in the proportions in which they bear the economic risk of loss, with respect to the Member Nonrecourse Debt partner nonrecourse debt to which such Member Partner Nonrecourse Deductions are attributable in accordance with Regulations Regulation Section 1.704-2(i)(12(i).
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Calamos Asset Management, Inc. /DE/), Limited Liability Company Agreement (Calamos Asset Management, Inc. /DE/), Limited Liability Company Agreement (Calamos Asset Management, Inc. /DE/)
Partner Nonrecourse Deductions. Any Member All Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member Partner who bears the economic risk of loss under Treasury Regulations § 1.752-2 with respect to the Member Partner Nonrecourse Debt to which such Member Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1)attributable.
Appears in 3 contracts
Samples: Limited Partnership Agreement (FD Spinco II, Inc.), Partnership Agreement (FD Spinco II, Inc.), Limited Partnership Agreement (FD Spinco II, Inc.)
Partner Nonrecourse Deductions. Any Member Nonrecourse Deductions partner nonrecourse deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt partner nonrecourse debt to which such Member Nonrecourse Deductions partner nonrecourse deductions are attributable in accordance with Regulations Treasury Regulation Section 1.704-2(i)(1).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (First Capital Real Estate Trust Inc), Limited Liability Company Agreement (First Capital Real Estate Trust Inc)
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Partner Nonrecourse Debt to which such Member Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1).
Appears in 2 contracts
Samples: Operating Agreement (Chesapeake Corp /Va/), Operating Agreement (Georgia Pacific Corp)
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member Owner who bears the economic risk of loss with respect to the Member Partner Nonrecourse Debt to which such Member Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1)section 1.7042(i)(1) of the Regulations.
Appears in 2 contracts
Samples: Alternative Servicing Agreement, www.studentloanlawworkshop.net
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Partner Nonrecourse Debt to which such Member Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(12(i).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (NorthStar Healthcare Income, Inc.), Limited Liability Company Agreement (Griffin-American Healthcare REIT III, Inc.)
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Partner Nonrecourse Debt to which such Member Partner Nonrecourse Deductions are attributable in accordance with Regulations Section Sections 1.704-2(i)(12(b)(4) and 1.704-2(i).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Nexpoint Diversified Real Estate Trust), Limited Liability Company Agreement (Jernigan Capital, Inc.)
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse ------------------------------ Deductions for any Fiscal Year fiscal year or other accounting period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt nonrecourse liability, as determined and defined under Regulations Section 1.704-2(b)(3) to which such Member Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1).
Appears in 1 contract
Partner Nonrecourse Deductions. Any Member Nonrecourse Partner nonrecourse Deductions for any Fiscal Year or other period shall be specially specifically allocated to the Member Members who bears bear the economic risk of loss with respect to the Member Partner Nonrecourse Debt to which such Member Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1)) of the Treasury Regulations.
Appears in 1 contract
Samples: Limited Liability Company Operating Agreement (National CineMedia, Inc.)
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Partner Nonrecourse Debt to which such Member Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i)(1).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Marsh & McLennan Companies Inc)
Partner Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section Sections 1.704-2(i)(12(b)(4) and 1.704-2(i).
Appears in 1 contract
Samples: Limited Liability Company Agreement (FC Global Realty Inc)
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse Deductions for any Fiscal Year shall will be specially allocated to the Member Partner who bears the economic risk of loss with respect to the Member Partner Nonrecourse Debt to which such Member the Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1).Treasury Regulations
Appears in 1 contract
Samples: CPG OpCo LP
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member Capital Account of the Unitholder who bears the economic risk of loss with respect to the Member Partner Nonrecourse Debt to which such Member Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1)) of the Regulations.
Appears in 1 contract
Samples: Agreement and Declaration of Trust (NT Equity Long/Short Strategies Fund)
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse Deductions for any Fiscal Year fiscal year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Partner Nonrecourse Debt to which such Member Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(12(i)(2).
Appears in 1 contract
Samples: Fourth Amended And (Developers Diversified Realty Corp)
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse Deductions for ------------------------------ any Fiscal Year or other period shall be specially allocated to the Member who that bears the economic risk of loss with respect to the Member Partner Nonrecourse Debt to which such Member Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i)(12(i).
Appears in 1 contract
Samples: Operating Agreement (Insight Communications Co Inc)
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss ofloss with respect to the Member Partner Nonrecourse Debt to which such Member Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1)2(i)(l) ofthe Tax Regulations.
Appears in 1 contract
Samples: www.sullivanida.com
Partner Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member Partner who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1).
Appears in 1 contract
Samples: Icos Corp / De
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member Shareholder who bears the economic risk of loss with respect to the Member Partner Nonrecourse Debt to which such Member Partner Nonrecourse Deductions are attributable in accordance with Regulations Section § 1.704-2(i)(1).
Appears in 1 contract
Samples: Shareholders’ Agreement (Cb Richard Ellis Realty Trust)
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse Deductions for any Fiscal Year fiscal year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Partner Nonrecourse Debt Liability to which such Member Partner Nonrecourse Deductions are attributable in accordance with Regulations Section Treas. Reg. § 1.704-2(i)(12(i).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Orgenesis Inc.)
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse ------------------------------ Deductions for any Fiscal Year shall be specially allocated to the Member Partner who bears the economic risk of loss with respect to the Member Partner Nonrecourse Debt to which such Member Partner Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1)) of the Regulations.
Appears in 1 contract
Samples: Brylane Capital Corp
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Partner Nonrecourse Debt to which such Member Partner Nonrecourse Deductions are attributable in accordance with Regulations Section section 1.704-2(i)(1)) of the Regulations.
Appears in 1 contract
Samples: Limited Liability Company Agreement (U S Energy Systems Inc)
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Partner Nonrecourse Debt to which such Member Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i)(1)2.
Appears in 1 contract
Samples: Operating Agreement (Excelsior Buyout Investors LLC)
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member Member(s) who bears the economic risk of loss with respect to the Member Partner Nonrecourse Debt to which such Member Partner Nonrecourse Deductions are attributable attributable, in accordance with Regulations Treasury Regulation Section 1.704-2(i)(12(i).
Appears in 1 contract
Samples: Loan Agreement (First Union Real Estate Equity & Mortgage Investments)
Partner Nonrecourse Deductions. Any Member Nonrecourse Deductions Partner nonrecourse deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss loss, or to the Members in the proportions in which they bear the economic risk of loss, with respect to the Member Nonrecourse Debt partner nonrecourse debt to which such Member Nonrecourse Deductions partner nonrecourse deductions are attributable in accordance with Regulations Regulation Section 1.704-2(i)(1).
Appears in 1 contract
Partner Nonrecourse Deductions. Any Member Partner Nonrecourse Deductions for any a Fiscal Year shall be specially allocated to the Member Partners who bears bear the economic risk of loss with respect to for the Member Nonrecourse Debt liability to which such Member Nonrecourse Deductions deductions are attributable in accordance with Regulations Section 1.704-1.704- 2(i)(1)) of the Regulations.
Appears in 1 contract
Samples: Limited Partnership Agreement
